Group health plan sponsors are required to complete an online disclosure
form with the Centers for Medicare & Medicaid Services (CMS) on an annual basis and at other select times, indicating whether the plan’s prescription drug coverage is creditable or non-creditable.
This disclosure requirement applies when an employer-sponsored group
health plan provides prescription drug coverage to individuals who are
eligible for coverage under Medicare Part D.
The plan sponsor must complete the online disclosure within 60 days after
the beginning of the plan year. For calendar year health plans, the deadline
for the annual online disclosure is March 1, 2022.
To determine whether the CMS reporting requirement applies, employers
should verify whether their group health plans cover any Medicare-eligible
individuals (including active employees, disabled employees, COBRA
participants, retirees, and their covered spouses and dependents) at the start of each plan year