The Centers for Medicare & Medicaid Services (CMS), requires Group health plans, including those offered by employers, to complete the Online Disclosure to CMS Form to report the creditable or non-creditable coverage status of their prescription drug plan(s) that are offered to Medicare Part D eligible individuals.

The Disclosure should be completed annually no later than 60 days from the beginning of a plan year (contract year, renewal year), or within 30 days after termination of a prescription drug plan, or within 30 days after any change in creditable coverage status.

In general, drug coverage is creditable if the expected amount of paid claims under the entity's prescription drug coverage is at least as much as the expected amount of paid claims under the standard Medicare prescription drug benefit. If you are unsure if the coverage offered through your plan(s) is creditable or non-creditable please refer to the 'creditable coverage simplified determination' or contact your GBAC account representative.

An entity is required to provide the Disclosure Notice through completion of the disclosure form on the CMS Creditable Coverage Disclosure Web Page. This method of transmission is convenient and will take minimal time to complete, and is the sole method for compliance with the requirement.

Note: you must report for each plan if you offer more than one Rx option.

CREDITABLE COVERAGE DISCLOSURE TO MEDICARE ELIGIBLE INDIVIDUALS

In addition to the required CMS reporting; employers must provide creditable or non-creditable coverage notice to all Medicare eligible individuals who are covered under, or who apply for, the entity's prescription drug plan (Part D eligibles) at least once a year.

This disclosure must be provided to Medicare eligible active working individuals and their dependents, Medicare eligible COBRA individuals and their dependents, Medicare eligible disabled individuals covered under your prescription drug plan and any retirees and their dependents.

Medicare beneficiaries who have other sources of drug coverage – through a current or former employer or union, for example – may stay in that plan and choose not to enroll in the Medicare drug plan. If their other coverage is at least as good as the new Medicare drug benefit (and therefore considered "creditable coverage"), then beneficiaries may continue to get the high quality care they have now as well as avoid higher payments later if they sign up for the Medicare drug benefit.

Eligible members who forego Part D enrollment when first available and who do not have creditable prescription drug coverage, for any period of 63 days or longer, will likely have to pay a higher Part D premium of one percent (1%) per month for late enrollment.

Employer plan sponsors are required by CMS to provide creditable coverage status to Part D eligible members at least once a year and at the following times:

• Prior to an individual's initial enrollment period;
• Prior to the effective date of coverage for any Medicare-eligible individual that joins your plan;
• Whenever prescription drug coverage ends or changes so that it is no longer creditable or becomes creditable;
• Prior to the Medicare Part D Annual Coordinated Election Period beginning on October 15 of each year; or
• Upon the request of a beneficiary.

This notice need not be a separate mailing and may be included with other plan participant informational materials and may be sent via electronic means.

Click here for Model Notice Letters you may use to meet this requirement.

Click here for additional information.

ABOUT GBAC

GBAC has been providing superior insurance products and services to businesses and families for over 35 years. Our dedicated team of benefit experts specialize in every type of insurance coverage. With unparalleled customer service, our mission is to provide the very best value to our clients. Let GBAC take some or all of the responsibility of managing your healthcare program and allow you more time to focus on your business. For more information, please call 203.239.3843.