Part D creditable coverage deadline calculator: when are the notice and the CMS filing due?
Enter your plan year start and any date your drug coverage changed to see the annual notice date and the CMS disclosure deadline. Built for HR teams that carry a prescription drug benefit and have two dates to hit every year.
Find your two Part D deadlines.
Set the plan year start. The dates update as you type.
The first day of the plan year.
Use this if the plan lost or gained creditable status during the year.
Your Part D dates
A planning estimate, not legal advice. The creditable determination comes from your carrier or an actuary. Confirm the dates with your plan administrator.
What are the two Part D duties?
An employer that offers prescription drug coverage to Medicare-eligible people has to tell them whether the coverage is creditable, meaning it is expected to pay out at least as much as standard Medicare Part D. The notice goes out each year before October 15. The employer also reports the status to the Centers for Medicare and Medicaid Services through its online form within 60 days after the plan year begins.
Who decides whether coverage is creditable?
The carrier or an actuary makes the determination, not the employer. A fully insured plan usually gets the answer from the carrier. A self-funded plan needs an actuarial test or the simplified method that CMS allows for some plans. The result can change as the Part D benefit itself changes, so the determination should be refreshed each year.
Common questions
Who gets the notice?
Every Medicare-eligible person covered by the plan or applying for it. That includes active employees, retirees, COBRA participants and covered dependents who are eligible for Medicare. Many employers send it to everyone to avoid missing someone.
What if the plan is not creditable?
The notice still goes out, and it says the coverage is not creditable. A person without creditable coverage who delays Part D can face a late penalty, which is why the notice matters.
Does a plan with no drug coverage need the notice?
The duty attaches to prescription drug coverage. If the plan has none, there is nothing to disclose, but confirm that with the carrier.
Who files with CMS?
The plan sponsor does, through the CMS online form. Some carriers and vendors will file on the employer’s behalf, so ask who owns it before the date.
Laws and rules referenced
42 C.F.R. § 423.56 — Medicare Part D creditable coverage notices and disclosure to CMS.
This tool gives estimates for education, not tax or legal advice. Rules change, so confirm your situation with a qualified advisor.
Talk to us about your Part D notices
Book a 30-minute call and we will confirm your creditable status and put both dates on the compliance calendar. Visit us at 41000 Woodward Avenue, Suite 350 East, Bloomfield Hills, MI 48304, or call 248.370.8853.
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