Each year, plan sponsors must disclose to CMS the group health care plan creditable coverage status for prescription drug coverage. This reporting is due within 60-days of the beginning of each new plan year. For plans that renew January 1, this is March 1st of the new plan year (technically February 29th in a leap year). In addition, the disclosure must be made within 30 days after the termination of the prescription drug plan, and within 30 days after any change to the creditable status of the prescription drug plan.
This reporting is distinct from the required Medicare Part D creditable/non-creditable coverage notice that is provided to participants, prior to October 15th of each year.
The annual report to CMS is an online report completed by the plan sponsor. Occasionally, a report may be submitted with incorrect information such as the wrong plan year or wrong employer identification number (EIN). The guidance does not provide a process for correcting a previously filed report. The online form does not have a section for marking the report as “corrected” either. If an incorrect report has been filed, the best course of action is to refile a correct report as soon as possible. If the report has not been timely filed, the report should be filed as soon as possible. Although there are no specific penalties that apply to this reporting requirement, it is a requirement, and the plan sponsor should attempt to provide the most accurate report possible.
CMS guidance with screenshots is available here.
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