All group health plans that provide prescription drug coverage to Medicare Part D eligible individuals (whether actively working, retired, or disabled) are required to notify CMS whether or not the Rx coverage offered by the employer is “creditable” within 60 days of the start of the plan year.
For plan sponsors that renew January 1, disclosure are due to CMS by March.
This disclosure is required whether the coverage is primary or secondary to Medicare. Employers must file their Disclosure Notice through the CMS website. It only takes a few minutes to complete the disclosure and remain in compliance.