Employers offering group health plans with prescription drug coverage to individuals who are also eligible for Medicare Part D must comply with certain disclosure requirements as outlined by the Centers for Medicare & Medicaid Services (CMS).

They must disclose, for example, if their prescription drug coverage is at least as good as the Medicare Part D coverage – or if their coverage is "creditable". These disclosures must be provided on an annual basis and at certain other designated times.

The annual federal Medicare Part D “Notice of Creditable or Non-Creditable Coverage” notice must be sent to employees by October 14, 2025.

Here's how the process works:

1. Send the Medicare Part D Notice of Creditable or Non-Creditable Coverage to your employees and COBRA participants by October 14, 2025 (if you need a list of COBRA participants, please let us know).
2. Make sure the notice is included in all new hire packets.
3. Complete and submit the Disclosure to CMS form electronically.

Download the following items:

• Memo: this document explains your tasks and how to determine if your plan is "creditable" or "non-creditable". The attached memo includes both the 2025 and 2026 "non-creditable" plans.
• Non-creditable coverage notice: if your plan is "non-creditable", you will send CMS Form 10182-NC.
• Creditable coverage notice: if your plan is "creditable", you will send CMS Form 10182-CC.
• Medicare coverage form: send this document with the Creditable Coverage notice. Only individuals that have Medicare coverage need to complete and return this form to ensure that we are correctly coordinating their health insurance benefits.

Important to note: if you offer two plans and their creditability is different, you need to provide the appropriate notice to the plan selected by your employee.

NOTE: This material is not considered legal advice. If you offer additional prescription drug benefits, please seek information from the appropriate carrier.