Reminder: Creditable Coverage Disclosure Required of Entities Offering Drug Coverage to Medicare Beneficiaries

Companies/entities offering prescription drug coverage to people eligible for Medicare Part D are required to disclose to the Centers for Medicare and Medicaid Services (CMS) whether their prescription drug coverage is considered ‘creditable’ or not. This disclosure must be made to CMS on an annual basis, or upon any change that affects whether the coverage is creditable. It is also required regardless of whether the coverage offered is primary or secondary to Medicare. See CMS’ document “Entities Required to Provide Disclose to All Medicare Eligible Individuals” for a list of who this requirement applies to. Companies that contract with Medicare directly as a Part D plan or that contract with a Part D plan to provide qualified prescription drug coverage are exempt from this disclosure requirement.

The Disclosure to CMS Guidance and Disclosure to CMS Form can be found on the CMS website at

Entities are also required to disclose information regarding creditable coverage to all Medicare beneficiaries who are covered by, or who apply for, prescription drug coverage under their plan. CMS provides model notices and language for companies to use, though they are not required. The Disclosure to CMS guidance and Disclosure to CMS form can be found on the CMS website. Disclosure of Creditable Coverage to Medicare Part D Eligible Individuals Guidance contains both sample notices and a list of the required elements a disclose notice must contain.

Basically entities are required to state:

  • whether their coverage is considered ‘creditable,’
  • a definition of creditable coverage,
  • why creditable coverage is important for preventing any future premium penalty if the beneficiary chooses to enroll into a Medicare Part D plan at a future time, and
  • an individual’s rights to receive and/or request a notice regarding creditable coverage.

For more information on creditable coverage, disclosure forms and guidance, visit the CMS website at

Karen Joy Fletcher

Our blogger Karen Joy Fletcher is CHA’s Communications Director. With a Masters in Public Health from UC Berkeley, she is the online “public face” of the organization, provides technical expertise, writing and research on Medicare and other health care issues. She is responsible for digital content creation, management of CHA’s editorial calendar, and managing all aspects of CHA’s social media presence. She loves being a “communicator” and enjoys networking and collaborating with the passionate people and agencies in the health advocacy field. See her current articles.