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Medicare Creditable Coverage Disclosure to CMS Required by February 29 for Calendar Year Plans

January 30, 2024

Entities that provide prescription drug coverage to Medicare Part D eligible individuals must disclose to Center for Medicare and Medicaid Services (CMS) whether the coverage is "creditable prescription drug coverage". This disclosure is required whether the entity's coverage is primary or secondary to Medicare. More information is available on the CMS website.


The disclosure should be completed annually no later than 60 days after the beginning date of a plan year for which the disclosure is being reported (contract year, renewal year), within 30 days after termination of a prescription drug plan, or within 30 days after any change in creditable coverage status. Calendar year plans would need to disclose by February 29th due to the leap year. Typically it falls on March 1st.


Entities must disclose creditable coverage status to CMS using the online Disclosure to CMS Form which is also on the site above and can be found here. For instructions and guidance on Creditable Coverage Disclosure to CMS, please refer to the documents found under "Downloads" on the CMS website link.


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