Annual CMS Medicare Part D disclosure due for calendar year plans

As part of the annual notification requirements under the Medicare Modernization Act, employer-sponsored group health plans that provide prescription drug coverage are required to disclose the plan’s creditable or non-creditable coverage status to the Centers for Medicare & Medicaid Services (CMS). This online disclosure is due 60 days after the first day of each plan year, which is March 2, 2023 for 2023 calendar year plans.

This Alert provides a summary of the disclosure requirements, including a review of:

• The employers subject to disclosure; 
• The timing of the disclosure; 
• The general contents of the disclosure; and 
• Available CMS guidance and instructions.