Compliance Bulletin: Medicare Part D Disclosure due to CMS by 3/1/19

Disclosures due by March 1, 2019 for Calendar Year Plans

  • Employers with health plans that provide prescription drug coverage to individuals who are eligible for Medicare Part D are subject to certain disclosure requirements.

  • Plan sponsors must complete an online disclosure form with CMS within 60 days after the start of the plan year, or March 1, 2019, for calendar year plans.

Click for online CMS Disclosure form


March 1, 2019

Deadline for sponsors of calendar year plans to complete an online disclosure form with CMS.

October 14, 2019

Deadline for group health plan sponsors to provide creditable coverage disclosures to Medicare-eligible individuals.

COMPLIANCE TIP: If an employer’s group health plan does not offer prescription drug benefits to any Medicare Part D eligible individuals (including active employees, disabled employees, COBRA participants, retirees, and their covered spouses and dependents) as of the beginning of the plan year, the group health plan is not required to submit the online disclosure form to CMS for that plan year.
Bunny Pratt