Background Information
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Employers offering prescription drug benefits within Group Health Plans are required by the Medicare Part D regulations to distribute a notice of Creditable or Non-Creditable prescription drug coverage to Medicare-eligible employees and retirees by October 14 each year. Creditable means the coverage is “as good as” and comparable to Medicare Part D coverage.
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In addition to this notice to Medicare-eligible employees, employers must also report to the Centers for Medicare and Medicaid Services (CMS) as to their plan(s)’ Creditable or Non-Creditable status.
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Reporting is due to CMS within 60 days of the beginning of the plan year; within 30 days after termination of a prescription drug plan; or within 30 days after any change in Creditable or Non-Creditable coverage status.
CMS Online Reporting Form
CMS REPORTING REFERENCE CHART
Timeline To Report Creditable Or Non-Creditable Rx Coverage to CMS Online
| If Plan Year Begins | Report Online to CMS By: | If Plan Year Beings: | Report Online to CMS By: |
| January 1 | March 1 | July 1 | September 1 |
| February 1 | April 1 | August 1 | October 1 |
| March 1 | May 1 | September 1 | November 1 |
| April 1 | June 1 | October 1 | December 1 |
| May 1 | July 1 | November 1 | January 1 |
| June 1 | August 1 | December 1 | February 1 |
Please contact your representative with any questions.
Unison Risk Advisors Compliance Team | benefitscompliance@unisonriskadvisors.com
Disclaimer: Materials are solely for informational purposes as an educational resource. Please contact counsel to obtain advice with respect to any specific issue.
