Required Reporting of Creditable Status to CMS

Required Reporting of Creditable Status to CMS

In addition to the disclosure requirements to eligible individuals, plan sponsors of prescription drug plans are also required to report to CMS annually, within 60 days after the beginning of the plan year. For example, for a 2026 calendar year plan, the employer should report by early March 2026 on whether the coverage offered for 2026 is creditable or non-creditable. This reporting requirement is separate and distinct from the §111 Medicare Secondary Payer reporting requirements that are due to CMS on a quarterly basis and typically handled by the insurance carrier or administrator. Reporting to CMS on the creditable status of the prescription drug coverage is generally not done by the insurance carrier or third-party administrator (TPA) but instead must be done by the employer. This reporting is done electronically. The instructions and online form for reporting creditable status to CMS can be found here – Disclosure to CMS Guidance and Instructions | CMS

How to Report

• CMS has provided detailed instructions that include screen shots, which can be found here: CreditableCoverageDisclosureUserManual05292012.pdf
• The electronic submission form is here – https://surveys.cms.gov/jfe/form/SV_6ilHtZUoAtl92n4

Information Needed to Complete the Reporting

General employer information – Employers should report using the name and federal ID number (EIN) of the plan sponsor. If multiple employers within a controlled group are covered under the same plan, the EIN for the parent company (or other entity if it is the plan sponsor) may be used under a single filing. If each individual entity reports separately, each should report using its own EIN. The EIN of the insurance carrier or third-party administrator should not be used.

Type of coverage – Most employers will choose “Group Health Plan: Employer Sponsored Plan,” but there are also options for church plans and state and local government plans.

Plan option information – Employers must report the number of prescription drug options offered and the creditable or non-creditable coverage status for each (i.e., number of group health plan options offered with different prescription drug benefits).

Estimated number of Medicare Part D individuals covered under each plan – CMS will accept a reasonable estimate of how many Medicare-eligible individuals are expected to be covered under the plan. Remember that dependents can be Medicare-eligible, and eligibility may be based on age, disability, end-stage renal disease (ESRD) or amyotrophic lateral sclerosis (ALS). The form also asks how many Medicare-eligible individuals are expected to be covered by a retiree plan. If the employer offers retiree coverage, the employer should indicate how many Medicare-eligible individuals are expected to be covered by the retiree coverage; if the employer does not offer retiree coverage, “0” should be entered.

Date of creditable coverage notice distribution – The most recent date (MM/DD/YYYY) that the required annual creditable or non-creditable Medicare Part D Notice was distributed to participants.