Employers with health plans that provide prescription drug coverage to Medicare-eligible individuals must disclose to CMS whether that coverage is creditable or noncreditable. This annual disclosure generally must be completed within 60 days after the start of the plan year.
Recent updates to the simplified determination methodology for 2026 and 2027 may affect how employers evaluate whether their prescription drug coverage is considered creditable. Employers should review plan options, disclosure timing, and available CMS resources with their advisors.
Our latest bulletin provides an overview of Medicare Part D disclosure requirements, creditable coverage considerations, and key deadlines employers should keep in mind. Download the full bulletin for a closer look at what employers should review.
This Compliance Update is not intended to be exhaustive, nor should any discussion or opinions be construed as legal advice. Readers should contact legal counsel for legal advice.
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