Because 2016 is a leap year, your Medicare Part D Disclosure to CMS may be due a day earlier than you are expecting.
Employers who sponsor group health plans that cover any prescription drugs generally must disclose whether the plan provides creditable or non-creditable prescription drug coverage to CMS within 60 days of the start of a new plan year. If your plan year begins on January 1, this normally means that you must file your disclosure with CMS by March 1. Since 2016 is a leap year, the 60-day deadline falls on Monday, February 29, 2016.
Filing is done electronically using the CMS Website. Instructions also are available there.
This filing requirement applies to health plans that cover anyone eligible for the Medicare Part D prescription drug program, whether as an active employee, spouse, dependent or retiree. There are limited exemptions for plans that contract with a Medicare Part D plan or directly with Medicare to become a Part D plan. Most employer-sponsored plans do not fall within these limited exceptions.
This disclosure is in addition to the Notice of Creditable (or Non-creditable) Coverage that you provide annually to Medicare-eligible participants. Remember also that if, after filing this disclosure, you terminate prescription drug coverage or change from creditable to non-creditable coverage (or vice versa), you must file a new electronic disclosure within 30 days and provide an updated notice to participants in your plan.
If you have any questions about the creditable coverage disclosure to CMS, or about Medicare Part D generally, please contact Norbert Kugele at nkugele@wnj.com or 616.752.2186; or April Goff at agoff@wnj.com or 616.752.2154.
