Q.- We have an insured health plan that offers prescription drug coverage. Since our plan is insured, do we have to complete the Medicare Part D online disclosure on the CMS website?
A.- Yes. The disclosure requirement is a plan sponsor (employer) requirement. Entities that provide prescription drug coverage to Medicare Part D eligible individuals must disclose to CMS whether the coverage is "creditable prescription drug coverage". This disclosure is required whether the entity's coverage is primary or secondary to Medicare. CMS requires that a Plan Sponsor provide an attestation that its prescription drug coverage is at least actuarially equivalent to the standard prescription drug coverage under Part D as part of the application for the Retiree Drug Subsidy (RDS).