- Posted by Jessica Waltman
- On February 18, 2020
All employer plans that offer prescription drug benefits must file an annual Medicare prescription drug disclosure form with the Centers for Medicare and Medicaid Services (CMS) about their coverage offerings. The due date is no later than 60 days after the beginning of each plan year, so if your new plan year started on January 1, that means your certification is due by February 29 of this year.
The report to CMS must specify if the coverage you provide is “creditable coverage,” and will likely cover, on average, as much as the standard Medicare Part D prescription drug plan. Employers need to assess each plan they offer separately and file a disclosure for each coverage option with prescription benefits that the company provides. To determine the status of your plan, check with your insurance carrier if you offer fully-insured coverage. Employers can also use the simplified determination guidance from CMS to assess the state of most prescription drug plan options.
If your plan does not pass the creditability test, don’t worry! There is no requirement that benefits must qualify as Medicare creditable coverage, and there is no penalty for not offering it. Your company just needs to report on the status of each plan option to CMS honestly and in a timely manner.
The procedure for notifying CMS about a plan’s creditable coverage status is very straightforward. Just access this simple online form, enter the plan’s contact information and the business’s federal tax identification number, and then complete the certification. The process only takes a few minutes. If you have any questions about the certification, please reach out to your benefits consultant.