Reminder for Employers: Medicare Part D Disclosures Due by February 28 for Calendar Year Plans
Group health plan sponsors are required to complete an online disclosure form with the Centers for Medicare & Medicaid Services (CMS) on an annual basis and at other select times, indicating whether the plan’s prescription drug coverage is creditable or non-creditable.
This disclosure requirement applies when an employer-sponsored group health plan provides prescription drug coverage to individuals who are eligible for coverage under Medicare Part D.
The plan sponsor must complete the online disclosure within 60 days after the beginning of the plan year. For calendar year health plans, the deadline for the annual online disclosure is February 28, 2025.
Important Dates
February 28, 2025: Deadline for sponsors of calendar year plans to complete an online disclosure form with CMS. Employers with other effective dates should notify CMS within 60 days of their renewal date.
October 15, 2025: Deadline for group health plan sponsors to provide creditable coverage disclosures to Medicare-eligible individuals. (If you provide the current year’s Annual Notices packet prepared by ARC Benefit Solutions to your employees, you have satisfied this requirement.)
Action Steps
To determine whether the CMS reporting requirement applies, employers should verify whether their group health plans cover any Medicare-eligible individuals (including active employees, disabled employees, COBRA participants, retirees, and their covered spouses and dependents) at the start of each plan year.
Employers that are required to report to CMS should work with their ARC representative to determine whether their prescription drug coverage is creditable or non-creditable. They should also visit CMS’ creditable coverage website, which includes links to the online disclosure form and related instructions.
Contact your ARC representative with any questions.
