As most Group Health Plans are likely already aware, they are required to notify the CMS every year as to whether their drug coverage is “creditable” or “non-creditable” for Medicare Part D purposes. This notice must be mailed to all Medicare Eligible plan participants annually before Oct 15.
in addition to the mailing
, the CMS requires a separate online disclosure notification for the Plan, which must be completed
electronically on the CMS website
. The information collected by the disclosure includes:
- Basic organization information (tax ID, address, etc.);
- Creditable coverage status for all plan options offered to employees;
- Date creditable coverage notices were mailed;
- Number of Medicare Part D Eligible individuals expected to be covered by a plan option during the plan year (it is acceptable for this to be a "good faith" estimate);
- Number of Medicare Part D Eligible individuals stated above who are expected to be covered through an Employer/Union Retiree Group Health Plan (i.e. the number above that are retired but not approved under the RDS program).
It is important to note that while there is not a published penalty for the Group Health Plan for non-compliance with this requirement, individuals may face late enrollment penalties.
Therefore, it is highly recommended that you complete the mailing and disclosures. This disclosure should be done within 60 days after the start of the health plan year.
As always, Part D Advisors is happy to address any questions, comments or concerns about CCNs, the Retiree Drug Subsidy program or Medicare in general that may arise. Please don't hesitate to reach out at any time.