Medicare Part D CMS Notification Reminder

Employers sponsoring a group health plan (whether insured or self-insured) need to report information on the creditable (or non-creditable) status of the plan’s prescription drug coverage to the Centers for Medicare and Medicaid Services (“CMS”).

In order to provide this information, employers must access CMS’s online reporting system at: https://www.cms.gov/Medicare/Prescription-Drug-Coverage/CreditableCoverage/CCDisclosureForm.html.

As a reminder, notice must be provided by the following deadlines:

• Within 60 days after the beginning date of each plan year;
• Within 30 days after the termination of the prescription drug plan; and
• Within 30 days after any change in the creditable coverage status of the prescription drug plan.

For example, an employer with a calendar year plan (January 1 – December 31, 2025) must complete this reporting no later than March 1, 2025.

If there was a change in the creditable coverage status of a prescription drug plan offered by the employer (e.g., from creditable to non-creditable, or vice versa), notice should be provided to CMS within 30 days of the change. For example, if a change occurred in connection with the January 1, 2025 plan year, CMS should be notified by January 31, 2025.

Employer Action

• For calendar year 2025 plans, timely complete reporting with CMS. For non-calendar year plans, timely complete reporting with CMS following the start of your 2025 plan year.
• You will need to have the following information ready to include when you complete the CMS online reporting:
  • The creditable (or non-creditable) status of prescription drug coverage provided by all plan options available to employees.
  • The date that the annual creditable (or non-creditable) coverage notice was furnished to Part D eligible individuals. You may have included this notice with open enrollment materials or sent it following the start of the plan year.
  • An estimate of the number of Medicare Part D eligible individuals covered under the plan. This does not have to be an exact number.

Additional resources for completing the form are available at:

• https://www.cms.gov/Medicare/Prescription-Drug-Coverage/CreditableCoverage/CCDisclosure.html
• Disclosure to CMS Form User Guide with screenshots: https://www.cms.gov/medicare/prescription-drug-coverage/creditablecoverage/downloads/ccuserguide.pdf