Information Needed to Complete Disclosures
In preparing the disclosure to CMS, plan sponsors need to:
- Identify the number of prescription drug options they offer to Medicare-eligible individuals. This is the total number of benefit options they offer. For example, a plan sponsor with a three PPO plan options available under its plan would identify three prescription drug options.
- Determine the number of benefit options offered that are creditable coverage and the number that are non-creditable.
- Estimate the total number of Part D-eligible individuals expected to have coverage under the plan at the start of the plan year (or, if both creditable and non-creditable coverage options are offered, estimate the total number of Part D-eligible individuals expected to enroll in each coverage category). This includes Part D-eligible active employees and disabled individuals and any of their Part D-eligible dependents, and any individuals on COBRA who are Part D-eligible. The estimate should not include any Part D-eligible individuals being claimed under the RDS program.
Note: Individuals who will become Part D eligible after the start of the plan year should not be included in the count for that year, but they must be provided a notice of creditable or non-creditable coverage prior to their initial enrollment period for Part D.
- State the most recent calendar date on which the required notices of creditable or non-creditable coverage were provided.