Sarah Borders, CEBS February 3, 2025 2 min read

Medicare Part D Coverage Disclosures Due January 31 or February 28 for Calendar Year Plans

Any sized employer who sponsors a group health plan is required to notify CMS of the plan’s Medicare Part D creditable coverage status.

 

Applies To:

All employers with a fully insured, level-funded, or self-funded group medical plan or an ICHRA

 

Go Deeper:

Disclosure must be done through an online form available on the CMS website. Hard copies are typically not allowed, unless the company has no internet access.

The form is relatively straightforward, but the employer needs to determine whether the prescription drug plan covers any Medicare-eligible individuals at the start of the plan year, including active employees, retirees, disabled individuals or anyone on COBRA. However, if the employer sponsors a Medicare retiree drug subsidy, participants of that plan should be excluded.

Employers may not be able to give an exact number of Part D eligible individuals, but should instead estimate the number of covered Part D eligible individuals described above.

The disclosure to CMS must be submitted annually within 60 days from the start of the plan year, or within 30 days if creditable status has changed for one or more plan options (or if all prescription drug plans have terminated). Thus, for plans that begin on January 1, the deadline to submit the CMS disclosure is either February 28, 2025, or January 31, 2025.

Lastly, there is no specific penalty for failure to complete the disclosure to CMS, but this filing requirement is one of the easiest and on average takes less than five minutes.

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Sarah Borders, CEBS

Principal, Benefits Compliance Solutions. Sarah has spent the last 15 years in the employee benefits industry, has numerous designations and serves on NAHU’s Employer Working Group Subcommittee and is an active board member of Austin AHU. She recently stepped down as Vice President of Benefits Compliance at one of the nation's largest brokerage firms to start her own compliance consulting practice. Her designations include an active license with the Texas Department of Insurance, CEBS (Certified Employee Benefits Specialist), Certified Health Care Reform Professional, HIPAA certification and Health Care Service Associate. She holds an MBA from Texas A&M Corpus Christi and a BA from University of Incarnate Word. Her consulting firm, Benefits Compliance Solutions, partners with employers to identify unknown risks and avoid hundreds of thousands of dollars in fines and lawsuits from failure to comply with their healthplan obligations.

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