Healthcare Compliance Corner

Medicare Part D Disclosure Requirements

Entities that provide prescription drug coverage to Medicare Part D eligible individuals must disclose to CMS whether the coverage is “creditable prescription drug coverage”. This disclosure is required whether the entity’s coverage is primary or secondary to Medicare. Entities must disclose creditable coverage status to CMS using the online Disclosure to CMS Form. Additionally, entities must provide a written disclosure notice to all Medicare eligible individuals annually who are covered under its prescription drug plan, prior to October 15th each year. If you are a Health & Welfare client, Conrad Siegel’s team prepares this written disclosure notice for you to provide to benefit eligible individuals.

Who Must Provide the Disclosure to CMS Form

Entities include:

  1. Group health plans, including those offered by employers; union/Taft-Hartley plans; church plans; Federal, State and local government plans; and other group-sponsored plans.

Timing of Creditable Coverage Disclosure to CMS Form from Entity

The Disclosure to CMS Form must be submitted to CMS on an annual basis, and upon any change that affects whether the drug coverage is creditable.

To complete the form go to:

If you need assistance finding out if your plan is creditable, contact your client manager for more information.