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Creditable Coverage Disclosure to CMS

REMINDER: Creditable Coverage Disclosure to CMS
Calendar Year Plans: March 1, 2011 deadline

Entities that provide prescription drug coverage to Medicare Part D eligible individuals must disclose to CMS on an annual basis if their coverage qualifies as creditable or non-creditable. This disclosure is required whether the entity’s coverage is primary or secondary to Medicare and is made through completion of the Disclosure to CMS Form (Form CMS-10198) which can be found on the CMS website: https://www.cms.gov/CreditableCoverage/45_CCDisclosureForm.asp.  The on-line transmission is the sole method of providing notice to CMS.
 
The entities which must complete the Disclosure to CMS Form include: 
  • Group health plans, union/Taft-Hartley plans; church plans; Federal, State and local government plans; and other group-sponsored plans;
  • Government sponsored plans (including Medicaid, State Pharmaceutical Assistance Programs and State High Risk Pools);
  • Military coverage
  • Individual health insurance;
  • Indian health Service; Tribe or other Tribal Organizations; Urban Indian Organizations; and
  • Medigap plans (including standardized plans H, I, or J); pre-standardized plans; waiver State plans, and plans with innovative benefits.
 The Disclosure to CMS Form must be submitted 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. For example, plans that run on a calendar year must submit disclosure to CMS by March 1, 2011.
  •  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.
 If you have any questions on providing the Disclosure to CMS Form, please contact a member of your Banyan consulting team.