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CMS Medicare Part D Reporting | Upcoming Deadlines

oswaldcompanies February 12, 2016
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Background Information

Notice and Reporting of Creditable or Non-Creditable RX Coverage

If employers offer prescription drug benefits within Group Health Plans, Medicare Part D regulations require employers to distribute a notice of Creditable or Non-Creditable prescription drug coverage to Medicare-eligible employees and retirees by October 14 each year.

In addition to the notice of Creditable or Non-Creditable coverage to Medicare-eligible employees by October 14 annually, employers must also report to the Centers for Medicare and Medicaid Services (CMS) Online as to the plan(s)’ Creditable or Non-Creditable prescription drug status.

These notification and CMS reporting requirements apply to all employers offering medical benefit plans that include prescription drugs. Reporting is due to CMS within 60 days of the beginning of the plan year; within 30 days after termination of a prescription drug plan; or within 30 days after any change in Creditable or Non-Creditable coverage status. See attached calendar for reference. 

HCRFeb12Chart

Further Resources:

Model Creditable Coverage Disclosure Notice


Oswald Companies | Health Care Reform Implementation Review

Danielle Jarvis | djarvis@oswaldcompanies.com; 216.649.7384

Luke Clark | lclark@oswaldcompanies.com; 216.367.8758

Marianne Ernst | mernst@oswaldcompanies.com; 216.367.4917

Disclaimer: Materials are solely for informational purposes as an educational resource. Please contact counsel to obtain advice with respect to any specific issue.

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