CMS Disclosures Due for Calendar-Year Plans By March 1st

Health plan sponsors are required to annually complete an online disclosure form with the Centers for Medicare and Medicaid Services (CMS) regarding whether the plan’s prescription drug coverage offered is “creditable,” meaning at least as good as Medicare Part D’s prescription drug benefit. The plan sponsor is required to complete this disclosure within 60 days of the beginning of the plan year if the plan has any participants who are eligible for and receiving Part D prescription drug benefits. For calendar year health plans, that means the disclosure is due by March 1, 2017. Plans that do not offer any Medicare-enrolled participants drug coverage do not need to complete the disclosure. Also, plans that receive the Medicare Part D drug subsidy (“RDS”) do not need to file with CMS.