Reminder to Complete Part D Creditability Reporting to CMS

All employers sponsoring a medical/Rx plan are responsible for completing 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.  Employers are responsible for going online and making a disclosure via the online form.

Deadline

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

For a calendar year plan, the 2022 reporting is due Wednesday, March 2, 2022 (or Monday, January 31, 2022, 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 it may be prudent to save the final screen as proof of submission, as the website does not provide a certificate of completion.

Info to Gather

CMS provides basic instructions, and it takes approximately 5 minutes to complete. A group health plan will need to report the following:

• The plan sponsor’s name and FEIN
• Whether the group health plan is an employer sponsored plan, union/Taft Hartley plan, church plan, or governmental plan
• Whether all the medical/Rx plans you offer are creditable, non-creditable, or a mix
  • Your insurer, TPA, or PBM should be able to identify the creditability of each plan you sponsor
• Approximate number of enrolled family members you estimate are eligible for Medicare as of the new plan year’s start date
  • If you are confident none of your enrolled employees are Medicare eligible but are unsure if any of their dependents might be, you can enter 0
• Last date notice was provided to employees about Part D creditability
  • If you included language about this in your fall annual open enrollment guide, feel free to use the date you provided open enrollment info
  • If you mailed a letter to employees in the fall before October 15, feel free to use the date you sent that letter

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

IMA will continue to monitor regulator guidance and offer meaningful, practical, timely information.

This material should not be considered as a substitute for legal, tax and/or actuarial advice. Contact the appropriate professional counsel for such matters. These materials are not exhaustive and are subject to possible changes in applicable laws, rules, and regulations and their interpretations.