Medicare Part D Notices and Reporting
Who Must Comply?
- Employers with group health plans that provide prescription drug coverage to individuals who are eligible for Medicare Part D
- Sponsors must disclose to individuals whether or not their prescription drug coverage is creditable, meaning it is at least as good as the Medicare Part D coverage.
- There are no specific penalties for employers that fail to comply with disclosure requirements.
What to Provide
- Plan sponsors must provide creditable coverage disclosure notices to individuals each year before Oct. 15—the start date of the annual enrollment period for Medicare Part D.
- The disclosure notice alerts individuals as to whether their plan’s prescription drug coverage is creditable.
- Model notices are available for employers to use.
Disclosure to CMS
- The disclosure to CMS is due within 60 days after the start of each plan year.
- For calendar year plans, this deadline is March 1 of each year (Feb. 29 for leap years).
- Plan sponsors are required to use CMS’ online disclosure form.