Reminder: Employers with Calendar Year Health Plans Must Complete Online CMS Disclosure by March 1, 2010 In addition to distributing Medicare Part D coverage notices to Medicare-enrolled employees, plans sponsors must also complete an annual on-line disclosure form with CMS. The plan sponsor must complete the disclosure within 60 days after the beginning of the plan year (sponsors of insured plans may choose to file within 60 days after the beginning of the insurance contract year). For calendar year health plans, this means filing with CMS by March 1, 2010. A CMS filing is also required within 30 days of termination of a prescription drug plan and for any change in creditable coverage status of a plan.

Employer plans that do not offer drug coverage to any Part D eligible individuals at the beginning of the plan year are exempt from filing. Similarly, employers who qualified for the retiree drug subsidy are exempt from filing with CMS, but only for the individuals and plan options for which they are claiming the subsidy. If an employer offers prescription drug coverage to any Part D eligible individuals who are not claimed under the subsidy, the employer must complete an on-line disclosure for plan options covering such individuals.

To learn more go to How Do I Complete My Online CMS Disclosure?