CMS Medicare Part D Disclosure Due by March 1, 2024

All fully insured and self-insured plans (including level-funded plans) of all sizes, including church and governmental plans, must annually disclose to CMS whether their plan’s prescription drug coverage is creditable. Generally, “creditable coverage” refers to prescription drug coverage that is expected to pay (based on the actuarial value) on average at least as much as Medicare Part D coverage.

The disclosure must be made to CMS within 60 days of the start of the policy or contract year. Accordingly, for calendar year prescription drug policies, the Medicare Part D disclosure is due to CMS by March 1, 2024.

For additional information about the disclosure to CMS, please download a copy of Medicare Part D Disclosures: A Guide for Employers. The publication includes links to the CMS website and instructions for accessing the disclosure form.