Medicare D: Disclosure to CMS – Reminder

As part of the Creditable Coverage requirements under the Medicare Modernization Act (MMA), entities 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 coverage that is provided is creditable through the Online Disclosure to CMS Form.  The Disclosure should be completed annually no later than 60 days from the beginning of a plan year (contract year, renewal year), within 30 days after termination of a prescription drug plan, or within 30 days after any change in creditable coverage status.

NOTE: If you are offering an actual Part D Plan, you are exempt from this filing requirement. Employers who have applied for a retiree drug subsidy are NOT required to complete this form.

You will need the following information to complete the Disclosure Notice:

  • Employer’s name, address and phone number;
  • Employer’s Federal Tax Identification Number (EIN);
  • Type of coverage (most will be Group Health Plan: Employer Sponsored Plan or Local Government);
  • Number of prescription drug plans offered by the employer;
  • Whether or not the prescription drug plans are creditable;
  • The plan year beginning and end dates, the estimated number of Part D eligible individuals expected to be covered under the plans, the estimated number of plan participants expected to be covered through an employer/union group health retiree plan, the date the Creditable Coverage Notice was distributed and whether or not the creditable coverage status has changed since the last disclosure;
  • Name, title, and email address of individual authorized to file the Disclosure Notice;
  • Date of disclosure to CMS.


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The information provided is for informational purposes only and does not constitute legal advice. The information above contains only a summary of the applicable legal provisions and does not purport to cover every aspect of any particular law, regulation or requirement. Depending on the specific facts of any situation, there may be additional or different requirements. This is to be used only as a guide and not as a definitive description of your compliance obligations.