Employers who provide prescription drug coverage must remember to file the online disclosure with the Centers for Medicare and Medicaid Services (CMS) about the creditability of that coverage. The disclosure must be made annually.
Medicare beneficiaries (those who are age 65 or older or otherwise eligible for Medicare) can receive prescription drug coverage under Medicare Part D. If an eligible individual does not enroll in Medicare Part D when first eligible, the individual may have to pay more for coverage if they enroll in Medicare Part D at a later date.
Individuals with prescription drug coverage through their employer may not be subject to a late enrollment penalty if that coverage is "creditable," which means it is at least as good as coverage available under Medicare Part D. Employers must inform their employees each year if the employer-provided prescription drug coverage is creditable or non-creditable.
In addition to the required notice to employees, employers must disclose the status of their prescription drug coverage to CMS. The disclosure must be made to CMS on an annual basis, within 60 days of the start of the plan year, within 30 days after termination of a prescription drug plan, and within 30 days after any change in the status of creditability of coverage.
The form is simple to complete and can be accessed online at https://www.cms.gov/Medicare/Prescription-Drug-Coverage/CreditableCoverage/CCDisclosureForm.html. For a calendar year plan, the disclosure must be completed by March 1, 2013.