Annual CMS Medicare Part D Disclosure

Employers sponsoring 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 1, 2024, for 2024 calendar year plans.

This alert provides a summary of the Medicare Part D disclosure requirements, including a review of timing and required contents of the disclosure. This alert is relevant for any employer that offers prescription drug benefits to employees (including former employees) and their dependents.