This requirement is nothing new. In the past health plan sponsors have been required to complete an annual online disclosure form with the Centers for Medicare and Medicaid Services (CMS), to show whether the prescription drug coverage offered under the sponsor’s plan/plans are “creditable” (at least as good as Medicare Part D’s prescription drug benefit) or “noncreditable” (not as good). The plan sponsor must complete the disclosure within 60 days after the beginning of the plan year.
Who Is Exempt From this Process?
As an employer if you do not offer drug coverage to any Medicare-enrolled employee, retiree or dependent at the beginning of the plan year are exempt from filing. Similarly, employers who qualified for the Medicare Part D retiree drug subsidy are exempt from filing with CMS, but only with respect to the individuals and plan options for which they claimed the subsidy. If an employer offers prescription drug coverage to any Medicare-enrolled retirees or dependents not claimed under the subsidy, the employer must complete an online disclosure for plan options covering such individuals.
Filing with CMS is due by March 1, 2014.
A CMS filing is also required within 30 days of termination of a prescription drug plan and for any change in a plan’s creditable coverage status. As described above some plans are exempt from the filing requirement.
Instructions related to the online filing discuss the types of information that are required, including the total number of Part D eligible individuals, the number of prescription drug options and which options are creditable and noncreditable. Click to access the instructions. Please save any documentation of this filing for your records.
Click to access the online portal that is used to complete the submission.