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Annual Medicare Part D reporting is required for all employers who provide health benefits with prescription drug coverage. The reporting is an online filing to the Centers for Medicare & Medicaid Services (CMS), and it lets CMS know if the prescription drug coverage available on the employer’s health plan is “creditable.”
The Medicare Part D reporting helps CMS determine if a person enrolling in a stand-alone Part D plan is subject to a late enrollment penalty. Late enrollment penalties are waived for individuals who delay enrollment in a Part D plan upon first becoming eligible unless they have prescription drug coverage elsewhere that is at least as good as the standard Part D plan (i.e. it is creditable coverage).
It is up to the employer to determine and report the creditable coverage status of their prescription benefits. Most employer plans will be considered creditable, but CMS has put together a simplified determination document to assist employers in that process.
The filing must be done on an annual basis, and it must be submitted within 60 days of the start of the plan year. Those employers with a calendar year plan should be preparing to submit their Medicare Part D reporting by March 1, 2019. The reporting is required for the employer regardless of whether the health plan is fully-insured or self-insured and regardless of whether the employer’s health plan is primary or secondary to Medicare.
The disclosure form to submit the reporting can be found by clicking here.
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