All employers sponsoring a medical/Rx plan are responsible for completing an online form with the Centers for Medicare and Medicaid Services (CMS) if any participant (employee, spouse, or dependent) might be eligible for Medicare Part D(Medicare’s prescription drug program).
This annual reporting indicates whether the employer’s prescription drug benefits are creditable or non-creditable compared to Medicare Part D. Employers are responsible for going online and making a disclosure via the online form.
Deadline
- Within 60 days of the plan renewal date, or
- Within 30 days if a plan’s creditable status changed or upon plan termination
For a calendar year plan, the 2022 reporting is due Wednesday, March 2, 2022 (or Monday, January 31, 2022, if one or more of the plan options changed creditability or terminated).
There is no express penalty to the employer for reporting late or failing to report, but it may be prudent to save the final screen as proof of submission, as the website does not provide a certificate of completion.
Info to Gather
CMS provides basic instructions, and it takes approximately 5 minutes to complete. A group health plan will need to report the following:
- The plan sponsor’s name and FEIN
- Whether the group health plan is an employer sponsored plan, union/Taft Hartley plan, church plan, or governmental plan
- Whether all the medical/Rx plans you offer are creditable, non-creditable, or a mix
- Your insurer, TPA, or PBM should be able to identify the creditability of each plan you sponsor
Please let your Bolton Benefits team know if you have any questions.
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