Blog > Medicare Part D CMS Notification Reminder: What Employers Need to Know

Medicare Part D CMS Notification Reminder: What Employers Need to Know

January 30, 2025

Employers who sponsor a group health plan, whether insured or self-insured, are required to notify the Centers for Medicare and Medicaid Services (CMS) regarding the creditable (or non-creditable) status of their plan’s prescription drug coverage. This important notification helps ensure that Medicare Part D eligible individuals are aware of their prescription drug coverage options.

Reporting Deadlines

Employers must submit this information within specific timeframes based on their plan year:

  • For calendar year plans (January 1 – December 31), the reporting must be completed no later than March 1, 2025.
  • For non-calendar year plans, the reporting should be completed within 60 days after the beginning of the plan year.

What Needs to Be Reported

When completing the CMS reporting, employers must provide the following information:

  1. Creditable (or non-creditable) status of prescription drug coverage for all plan options available to employees.
  2. Date the creditable coverage notice was provided to Part D eligible individuals. This notice can be part of open enrollment materials or sent after the start of the plan year.
  3. Estimate of the number of Medicare Part D eligible individuals covered under the plan. This estimate doesn’t have to be exact but should reflect the number of individuals who are eligible for Medicare Part D and are covered by your plan.

Accessing the CMS Reporting System

Employers can complete the reporting via CMS’s online portal, available at:
CMS Creditable Coverage Disclosure Form

When to Notify CMS of Changes

If there are any changes to the creditable coverage status (e.g., switching from creditable to non-creditable or vice versa), employers must notify CMS within 30 days of the change. For example, if the status change occurs on January 1, 2025, the notice should be submitted by January 31, 2025.

Key Takeaways

  1. Ensure timely reporting for calendar and non-calendar year plans.
  2. Provide the necessary information about the creditable status of prescription drug coverage.
  3. Notify CMS of any status changes within 30 days to stay compliant.

By following these guidelines and deadlines, employers can fulfill their obligations and avoid potential penalties. Remember, for calendar year plans, the March 1, 2025 deadline is fast approaching—make sure your report is submitted on time!

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