Valentine’s Day Reminder: Creditable Coverage Disclosure to CMS 

As Valentine’s Day approaches, love and fun are in the air, but so are important compliance deadlines! Plan sponsors must submit their Medicare Part D Creditable Coverage Disclosure to CMS by March 1st for calendar-year plans. While you’re busy planning surprises of love, don’t forget this essential compliance task. 

What Is Medicare Part D Creditable Coverage? 

Medicare Part D helps cover prescription drug costs for eligible beneficiaries. However, not all prescription drug plans are created equal. Creditable coverage refers to employer-sponsored drug plans that are at least as good as Medicare’s standard prescription drug coverage. 

Each year, employers and plan sponsors must determine whether their prescription drug plan is creditable or non-creditable and notify both their employees and the Centers for Medicare & Medicaid Services (CMS). 

Why Is the Creditable Coverage Disclosure to CMS Important? 

The Medicare Modernization Act (MMA) requires plan sponsors (whose policies include prescription drug coverage) to disclose whether their prescription drug coverage is creditable to CMS. This helps Medicare beneficiaries make informed decisions about enrolling in Part D without facing late enrollment penalties. 

Who Must Submit the Disclosure? 

Generally, group health plans that offer prescription drug coverage on a group basis to active and retired employees and beneficiaries who are Medicare eligible individuals.  

NOTE: This requirement applies to employers or unions that sponsor retiree coverage, regardless of whether those entities are eligible for, and elect to apply for, the retiree drug subsidy under Section 1860D-22 of the Social Security Act, 42 U.S.C. § 423.884. 

How to Submit the Creditable Coverage Disclosure? 

Filing the disclosure is a straightforward process that can be done online via the CMS Creditable Coverage Disclosure Form on the CMS website. Employers must: 

• Determine if their plan is creditable or non-creditable. 

• Submit the disclosure electronically through the CMS website. 

• Complete the submission no later than 60 days after the start of the plan year. 

Key Deadlines to Remember 

• February 14: A great time put together information for the CMS coverage disclosure while celebrating Valentine’s Day! 

• March 1, 2025: Deadline for calendar-year plans to submit the disclosure. 

• Within 60 days after the beginning of the plan year (contract year, renewal year, etc.) date for which the disclosure is provided; 

• Within 30 days after the termination of the prescription drug coverage provided by the Plan; and 

• Within 30 days after any change in the creditable coverage status of the prescription drug coverage provided by the Plan. 

Final Thoughts 

While Valentine’s Day is about love and appreciation, it’s also a great time to show your organization some love by ensuring compliance with Medicare Part D Creditable Coverage Disclosure to CMS.  For more information on creditable coverage 2025 updates, check out our blog on “Understanding Medicare Part D Notice Requirements for 2025” and the “Final CY 2025 Part D Redesign Program Instructions.” 

Happy Valentine’s Day—and happy filing!