Compliance Alert

Reminder to Complete Part D Creditability Reporting to CMS

February 12, 2018

All employers sponsoring a medical/Rx plan are responsible to complete an online form with the Centers for Medicare and Medicaid Services (CMS) if any participant (employee, spouse, or dependent) might be eligible for Medicare Part D (Medicare’s prescription drug program). This annual reporting indicates whether the employer’s prescription drug benefits are creditable or non-creditable compared to Medicare Part D. Insurers are not doing this reporting, so employers are responsible.

Deadline

• Within 60 days of every plan renewal date, or
• Within 30 days if a plan’s creditable status changed or the plan terminated

For a calendar year plan, the 2018 creditability reporting is due Thursday, March 1, 2018 or Tuesday, January 30, 2018, if one or more of the plan options changed creditability or terminated . There is no express penalty to the employer for reporting late or failing to report, but you may like to save the final screen as proof of submission anyway for your own records.

Info to Gather

As you’ll see in the instructions, CMS will require answering a few simple questions, including:

Whether all the medical/Rx plans you offer are creditable, non-creditable, or a mix, and dates Your insurer or TPA should be able to identify the creditability of each plan you sponsor

The last date you sent the required notice of creditable or non-creditable status to plan participants employees, COBRA, retirees, etc.)

These are due every year before October 15 when Part D’s annual open enrollment begins An estimate of the number of participants eligible for Medicare Part D

Don’t spend time estimating this…a ballpark idea is fine

If you don’t know of anyone eligible you can say zero or skip the reporting altogether (but remember to count COBRA, retirees, spouses, and dependents, and remember they can be eligible for Medicare due to age or disability)

Please let your IMA Benefits team know if you have any questions.