Reminder to Report Part D Creditability to CMS by March 1

For the last decade, the Centers for Medicare and Medicaid Services (CMS) has asked employers to provide them an update on the CMS website disclosing whether their renewing medical plan(s) have creditable or non-creditable prescription drug coverage.  Instructions with screenshots are provided on that site.

Most insurers or third party administrators (TPAs) will inform the employer whether prescription drug coverage is creditable (i.e., provides benefits at least as comprehensive as Medicare Part D).  Then the employer must report this status within 60 days of the start of the new plan year (or within 30 days of a change in creditability).

For calendar year plans, this means employers must report by March 1 (or by January 30 if creditability changed from 2018 to 2019).

There are a couple of limited exceptions available.

  • This reporting is not required with respect to a retiree plan receiving the Medicare Retiree Drug Subsidy, as CMS is already aware of these plans.

Also, if the prescription drug plan is not offered to anyone eligible for Medicare Part D at the beginning of the plan year (including employees, retirees, COBRA qualified beneficiaries, and any dependents), then creditability reporting is not required for that plan year.  However, employers may not know for sure whether dependents might be qualified for Part D, so it may be prudent for employers that believe they have no one eligible but can’t be sure to go ahead and do the reporting and just indicate they are aware of 0 individuals being eligible for Part D.

Please let your IMA Benefits team know if you have any questions; we will continue to monitor regulator guidance and offer meaningful, practical, timely information.

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