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March 1 Deadline Nears for Submission of Creditable Coverage Disclosures to CMS
Marsh Consulting Group
[Guidance Overview] Feb. 3, 2015
"[E]mployer-sponsored group health plans that offer prescription drug coverage to Part D-eligible individuals are required to submit an electronic Disclosure Notice to [CMS] on an annual basis. This requirement applies not only to employer-sponsored Retiree Health Plans (unless the plan applied for the Retiree Drug Subsidy Program), but also to employer-sponsored plans extended to active employees (and their covered spouses) who are enrolled or are Medicare-eligible (generally speaking, age 65 or over). This annual notice provides CMS with current information regarding the plan's creditable or non-creditable coverage status.... A plan sponsor must submit a new disclosure to CMS no later than 60 days after the beginning of each plan year -- i.e., by March 1, 2015 for calendar year plans."
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