Entities that provide prescription drug coverage to Medicare Part D eligible individuals must disclose to CMS whether the coverage is "creditable prescription drug coverage". Creditable coverage means that the coverage is expected to pay, on average, as much as the standard Medicare prescription drug coverage. This disclosure is required whether the entity's coverage is primary or secondary to Medicare.
For these entities, there are two disclosure requirements:
The first disclosure requirement is to provide a written disclosure notice to all Medicare eligible individuals annually who are covered under its prescription drug plan, prior to October 15th each year and at various times as stated in the regulations, including to a Medicare eligible individual when he/she joins the plan.
The second disclosure requirement is for entities to complete the Online Disclosure to CMS Form to report the creditable coverage status of their prescription drug plan. The Disclosure should be completed annually no later than 60 days from the beginning of a plan year (contract year, renewal year- which is typically March 1st), within 30 days after termination of a prescription drug plan, or within 30 days after any change in creditable coverage status. -- This requirement does not pertain to the Medicare beneficiaries for whom entities are receiving the Retiree Drug Subsidy (RDS).