Employers' Medicare Part D 2026 Creditability Disclosure Due March 1

Employers with medical plans that renew on January 1 must complete the Medicare Part D Creditable Coverage Disclosure to CMS by March 1, 2026. This requirement applies to any employer offering prescription drug coverage as part of a calendar‑year medical plan.
 

Overview

Federal law requires employers to provide two types of Medicare Part D notifications each year. The first is the annual notice to Medicare eligible employees confirming whether their prescription drug coverage is creditable, which must be distributed prior to October 15. The second requirement obligates plan sponsors to report the creditable coverage status of their prescription benefits directly to the Centers for Medicare and Medicaid Services within 60 days of the start of the plan year. For organizations with a January 1 renewal date, this means the CMS disclosure must be filed no later than March 1. Employers with plan years beginning on a different date must meet the same requirement within 60 days of their specific plan year start.
 

Mandatory Online Creditable Coverage Disclosure 

Nearly all employers must complete the online disclosure through the CMS website unless they participate in the Retiree Drug Subsidy program. The disclosure requirement extends beyond employer sponsored medical plans and includes individual health insurance, government assistance programs, military benefits, and Medicare supplement coverage. CMS does not offer any alternative submission method; compliance can only be met through the online questionnaire. Employers must also update their filing if the creditable coverage status of their prescription drug plan changes or if prescription drug benefits are eliminated. Click on the following link: CMS Disclosure Form.
 

Detailed Instructions and Screenshots are Available

For employers who need support with the submission process, CMS provides a comprehensive instruction guide. The guide includes step by step directions, screenshots, and explanations of the information required, making it easier to prepare and submit the disclosure accurately. Click on the following link: CMS Notification Instruction Guide.
 

Helpful Tip for Vita's Clients

Vita clients can find the Medicare Part D creditability status of their medical plans in the Welfare Summary Plan Description provided annually. This document includes all necessary creditability information and should be referenced when completing the CMS online disclosure.