Medicare Part D Disclosures Due by February 29th for Calendar Year Plans
The Medicare Modernization Act (MMA) requires organizations (whose policies include prescription drug coverage) to notify Medicare eligible policyholders whether their prescription drug coverage is creditable coverage, which means that the coverage is expected to pay on average as much as the standard Medicare prescription drug coverage. For these entities, there are two disclosure requirements:
The first disclosure requirement is to provide a written disclosure notice to all Medicare eligible individuals annually who are covered under its prescription drug plan, prior to October 15th each year and at various times as stated in the regulations, including to a Medicare eligible individual when he/she joins the plan.
The second disclosure requirement is for group health plan sponsors to complete the online disclosure form to the Centers for Medicare and Medicaid Services (CMS) to report the creditable coverage status of their prescription drug plan. The disclosure should be completed annually at the following times:
No later than 60 days from the beginning of a plan year (contract year, renewal year) OR Feb. 29, 2016 for calendar year plans;
Within 30 days after termination of a prescription drug plan; or
Within 30 days after any change in creditable coverage status.
If an employer’s group health plan does not offer prescription drug benefits to any Medicare-eligible individuals as of the beginning of the plan year, the group health plan is not required to submit the online disclosure form to CMS for that plan year.