Employers Must Disclose Medicare Part D Creditable Coverage to CMS by March 1,2011

The Medicare Modernization Act requires group health plan sponsors that offer prescription coverage to notify Medicare-eligible plan participants (employees and dependents) as to whether their prescription drug coverage is “creditable coverage”-which means the coverage is expected to pay on average as least as much as the standard Medicare Part D prescription drug coverage. Plan sponsors are also required to notify the Centers for Medicare and Medicaid Services (CMS) annually, via the CMS website. For calendar year plans, this notice must be provided to CMS no later than March 1, 2011.

Plan sponsors should go to the Online Disclosure to CMS Form at https://www.cms.gov/creditableCoverage/45_CCDisclosureForm.asp. Completing the online form is fairly simple. Employers must input the plan sponsor’s name, Federal ID number, address, phone number, type of coverage (a drop down box lists employer-sponsored GHP, Union GHP, government GHPs, church GHP, etc.), how many prescription drug options are offered under this coverage, and whether all or some of the options are creditable or non-creditable. Be sure to obtain a submission confirmation (step #3).