January 2006 Bulletin, "Guidance on Disclosing Medicare Part D Creditable Coverage Status to CMS"
The Centers for Medicare & Medicaid Services (CMS) recently issued guidance on the requirement under the Medicare Modernization Act of 2003 (MMA) for plan sponsors to disclose to CMS whether the plan's prescription drug coverage is "creditable" under Medicare Part D. Plan sponsors that are required to file the disclosure with CMS must do so by March 31, 2006.
This Bulletin summarizes answers in the recent guidance to the following questions regarding the CMS disclosure requirement:
- Which group health plans must notify CMS?
- In what form must the notice be provided?
- Who must submit the form?
- What information must be provided to CMS?
- What are the submission deadlines?
Although the form is relatively simple, given the difficulties experienced by many plan sponsors that applied electronically for the Retiree Drug Subsidy, plan sponsors would be well advised to review and submit this form as soon as possible.
This Bulletin concludes with a brief note on implications for plan sponsors, who should keep in mind that they may still need to file the CMS Disclosure even if their RDS application has been approved, as the Disclosure must be made for Part D-eligible actives and Part D-eligible retirees for whom the RDS is not claimed.