January 3, 2006
Guidance Issued by CMS (Creditable Coverage Notices)
On December 30, 2005, the Centers for Medicare & Medicaid Services (CMS) released guidance regarding the provision of creditable coverage notices by group health plans and others to CMS. The guidance, as well as the online form used to provide the notice, is available on the CMS website.
Mechanics of Reporting. The guidance indicates that the only manner by which a group health plan may provide a Creditable Coverage Disclosure to CMS is through the online completion of the disclosure form on the CMS creditable coverage web page. The group health plan must provide a number of pieces of information to complete the form, including, but not limited to, creditable coverage status, number of Medicare Part D eligible individuals expected to be covered under the plan as of the beginning of the plan year, and the date on which the plan provided the required creditable coverage disclosure to Part D eligible individuals.
Deadline. Generally, the notice must be provided on an annual basis within 60 days after the beginning of the plan year. Notice is also required if the plan is terminated or if the creditable coverage status of the plan changes.
Please Note: The initial disclosure, applicable to all plan years ending in 2006 (e.g., 2006 calendar plan years and plan years beginning in 2005) must be provided by March 31, 2006.
Left Open. The guidance did not address the provision of creditable coverage notices to Medicare Part D eligible individuals after the initial notice that was required by November 15, 2005. We expect CMS to issue such guidance in the near future. We will provide another alert to notify you when the guidance is released.
If you have any questions, please contact us.