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CMS Creditable Coverage Notice

In January 2006 the Centers for Medicare and Medicaid Services (CMS) implemented rules that require employers who offer prescription coverage to provide notification to their enrollees whether the coverage is creditable. Creditable Coverage is prescription drug coverage that is, on average, equal to or better than the basic Medicare Part D Coverage. This notice is called a Certificate of Creditable Coverage.

Annually Dean Health Plan reviews our prescription drug plans to determine whether they are creditable. Recently we have conducted our review for 2012, and have determined that all of our prescription drug plans are creditable for the upcoming year.

What do employers need to do?
Employer groups that offer prescription drug coverage to their employees must follow the notification requirements as explained on the CMS website. In general, the notice needs to be supplied to:

  • New enrollees before their enrollment

  • All current enrollees on an annual basis

  • All enrollees if the benefit levels of the prescription drug coverage change

Employers are also required to disclose to CMS whether the prescription drug coverage is creditable. The disclosure is done through completion of the Disclosure to CMS Form posted on the CMS Creditable Coverage webpage. This is the sole method for compliance with the requirement, unless and employer does not have internet access.

Timing of Creditable Coverage Disclosure to CMS Form from Entity
The Disclosure to CMS Form must be submitted to CMS on an annual basis, and upon any change that affects whether the drug coverage is creditable.

At a minimum, the Disclosure to CMS Form must be provided at the following times:

  • Within 60 days after the beginning date of the Plan Year for which the entity is providing the Disclosure to CMS Form.

  • Within 30 days after the termination of the prescription drug plan.

  • Within 30 days after any change in the creditable coverage status of the prescription drug plan.