Staying compliant with Medicare Part D requirements is essential if your business provides prescription drug coverage as part of a group health plan. Here’s what you need to know to ensure your plan meets federal guidelines and avoids penalties.
Who Needs to File a Creditable Coverage Disclosure?
Employers offering prescription drug coverage to Medicare Part D-eligible individuals—whether actively working, retired, or disabled—must file a form called the Creditable Coverage Disclosure Notice with the Centers for Medicare & Medicaid Services (CMS). This requirement applies whether the coverage serves as primary or secondary to Medicare.
However, there are two exceptions:
- You are exempt from this filing if your organization offers a Medicare Part D plan.
- Employers with a retiree drug subsidy are also not required to complete this form.
Filing Requirements and Deadlines
- Annual Filing: Employers must file a disclosure with the Department of Health and Human Services (HHS) within 60 days of the start of their plan year.
- Special Circumstances: In addition to the annual notice, employers must file:
How to File the Disclosure Notice
The Disclosure Notice must be filed through the CMS website, which provides detailed instructions and guidance for completing the process.
To complete the filing, you’ll need the following information:
- Employer’s name, address, and phone number.
- Employer’s Federal Tax Identification Number (EIN).
- Type of coverage (most will be “Group Health Plan: Employer Sponsored Plan” or “Local Government”).
- Whether the prescription drug plans offered are creditable.
- Name, title, and email address of the individual authorized to file the Disclosure Notice.
- Date of disclosure to CMS.
It’s worth noting that the CMS has simplified the form in recent years, making it easier to complete.
What Is Creditable Coverage?
Creditable coverage refers to prescription drug plans expected to pay as much as the standard Medicare Part D prescription drug plan. This designation is essential for Medicare-eligible individuals to avoid late enrollment penalties if they later choose to enroll in Medicare Part D.
Why This Matters
Filing the Creditable Coverage Disclosure is more than a compliance task—it ensures transparency for your employees and helps them make informed decisions about their healthcare coverage. Non-compliance can lead to penalties and confusion, so meeting the requirements on time is critical.
Need Assistance with Compliance?
At Webb Insurance, we understand that managing group health plans and staying compliant with Medicare Part D requirements can feel overwhelming. We’re here to guide you through the process, ensuring you have everything in place to meet filing deadlines and provide accurate information to your employees.
Contact Webb Insurance today to learn more about our group benefits services and compliance support. Call us at 717-637-3670 or visit our website for more details