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| Posted on: Thursday, October 12, 2006 |
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On December 30, 2005 the Centers for Medicare and Medicaid Services (CMS) posted instructions on their website detailing when and in what form entities that provide prescription drug coverage to Medicare Part D eligible individuals must report to CMS whether the pharmacy benefits offered are Medicare Part D “Creditable” or “Non-Creditable.”
A representative in your organization should follow the CMS Disclosure link below to complete and submit the required Disclosure Form. Employers must do so within 60 days after the beginning date of the Plan Year (plan renewal/anniversary date) for which the entity is providing the disclosure to CMS. This is not the responsibility of, and will not be done on your behalf by, your Claims Payor/TPA or Insurer.
For off-Calendar Year Plan Years, within the CMS disclosure report when it asks Date that the Annual Creditable Coverage Disclosure to Part D Eligible Individuals requirement was completed by the entity? you should insert the date within the last 12-months you sent Notice to Medicare-eligible individuals.
Determining Creditable vs Non-Creditable Status
The vast majority of employer medical plans provide "Credible Coverage.” Coverage is creditable if, on average, it is at least as good as standard Medicare prescription drug coverage. To assist you in determining whether your medical benefit plan(s) is or is not creditable, you may contact your insurance provider or visit our web article at Annual Notice Requirement to Medicare Part D Eligible Individuals
Guidance Posted on CMS Website
For a copy of the CMS guidance as it relates to the form, manner and timing your organization must submit the Disclosure Notice to CMS, go to www.cms.hhs.gov/CreditableCoverage.
Submitting the CMS Disclosure Notice
An entity must complete the online Disclosure Notice form by the required deadline, by going to the CMS Creditable Coverage Disclosure Web Page at https://www.cms.hhs.gov/CreditableCoverage/45_CCDisclosureForm.asp
Note: If an entity does not offer outpatient prescription drug benefits to any Medicare Part D eligible individuals on the beginning date of their Plan Year, the entity is not required to complete the Disclosure to CMS Form for that plan year.
Should you have any additional employee benefit questions or would like to discuss this material in detail, please don’t hesitate to call the Denman Team.
Denman does not offer legal or actuarial advice. The final decision as to the creditable or non-creditable status of a group health plan’s prescription drug coverage rests with the plan sponsor. |
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