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Medicare Part D: Know Your Reporting Duty to CMS

Is your group health plan fully complying with notification requirements associated with Medicare Part D?  The Medicare Prescription Drug Improvement and Modernization Act of 2003 requires all plan sponsors  -  even those who did not provide retiree prescription drug benefits  -  to distribute notices to Part D-eligible individuals explaining the creditable coverage status of their prescription drug benefits.  Typically, this notice is distributed by October 15 to correspond with the Medicare annual enrollment season.  In addition to the well-known Part D notice to participants, a sometimes more easily overlooked disclosure requirement to CMS is also required.  Specifically, the group health plan must communicate whether its prescription drug coverage qualifies as creditable or non-creditable.

The government needs this information to effectively coordinate Medicare Part D enrollment. All plan sponsors providing prescription drug coverage are required to make this disclosure, even if they do not make coverage available to retirees. Reporting to CMS about the plan's creditable status is due within 60 days after the first day of the new plan year. Calendar year plans must submit the disclosure to CMS by March 1, 2013

CMS requires electronic reporting of Part D creditable coverage status. To submit your report, visit the CMS website and complete the Disclosure to CMS online form. Guidance and instructions are also available online.