hmaa

Compliance Reminder for Employer Plans with Prescription Drug Coverage

All employers with a group health plan that provides prescription drug coverage to Medicare-eligible individuals must make an annual disclosure to the Centers for Medicare and Medicaid Services (CMS). The deadline is 60 days after the beginning of the plan year and/or no later than March 1, 2023 for calendar year 2022 plans. 

CMS disclosure screenshot

The disclosure includes whether or not the offered coverage is “creditable.” Prescription drug coverage is considered creditable if its actuarial value equals or exceeds the actuarial value of Medicare Part D. All HMAA prescription drug plans provide creditable coverage. 


Generally, Medicare-eligible individuals are age 65 or older, with some exceptions. If your drug plan provides coverage to any of these individuals, you are required to provide the following information to CMS:


  • Plan sponsor’s (usually the employer) name, address, federal tax ID number, and phone number
  • The name, title, and email address of the person completing the form
  • The type of coverage offered
  • The number of prescription drug coverage options available to Medicare-eligible individuals
  • The creditable coverage status of each prescription drug coverage option
  • The total number of Medicare-eligible individuals covered by each option


This disclosure is required whether the entity's coverage is primary or secondary to Medicare. If a plan’s prescription drug coverage is terminated or there is a change in the plan’s creditable coverage status, the employer must also disclose the updated information to CMS within 30 days.


Employers must disclose creditable coverage status to CMS online using the Disclosure to CMS Form. The form and additional information are available on the CMS website.

Disclosure to CMS Form

This notice is for informational purposes only, and does not constitute business or legal advice. 

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