[Updated 12/18/2018]

Medicare Part D Creditable or Non-Creditable Disclosure to CMS

The Medicare Modernization Act requires all employers to complete an Online Disclosure to CMS to report the creditable coverage status of their prescription drug plan. The prescription drug coverage is “creditable” if it is expected to pay, on average, as much as the standard Medicare prescription drug coverage (Medicare Part D); otherwise, it is “non-creditable.” The Online Disclosure should be completed annually no later than 60 days from the beginning of the plan year.


Action Item

  • Employers should ensure the Online Disclosure to CMS is completed within 60 days of the start of the plan year.  For example, employers with plan years beginning 1/1/2019 should submit their Online Disclosure to CMS no later than 3/1/2019.
  • The Online Disclosure can be completed here.
  • Once the online disclosure to CMS is completed, it is recommended that you take a screenshot or save the confirmation page for your records.


Sequoia clients: Be on the lookout for an e-mail from your Client Service Manager with the Online Disclosure instructions toward the beginning of your plan year.


More Information

Additional information is available on the CMS website. Please also refer to the Disclosure to CMS Guidance and Instructions.


The information and materials on this blog are provided for informational purposes only and are not intended to constitute legal or tax advice. Information provided in this blog may not reflect the most current legal developments and may vary by jurisdiction. The content on this blog is for general informational purposes only and does not apply to any particular facts or circumstances. The use of this blog does not in any way establish an attorney-client relationship, nor should any such relationship be implied, and the contents do not constitute legal or tax advice. If you require legal or tax advice, please consult with a licensed attorney or tax professional in your jurisdiction. The contributing authors expressly disclaim all liability to any persons or entities with respect to any action or inaction based on the contents of this blog.

Joanna Castillo– Joanna is the Client Compliance Manager for Sequoia, where she works with our clients to optimize and streamline benefits compliance. In her free time, Joanna enjoys live music, college football, travel, and walking her dog in Golden Gate Park.