<nobr>Mar 27, 2006</nobr>

CMS: Creditable Coverage Reminder

March 27, 2006
Memorandum to: ERIC Health Policy Committee

CMS REMINDER: CREDITABLE COVERAGE DISCLOSURE TO CMS DEADLINE MARCH 31, 2006; USER GUIDE & HELPFUL HINTS AVAILABLE ONLINE

CMS would like to remind affected entities and their advisors that the Medicare Prescription Drug, Improvement, and Modernization Act of 2003 requires entities that provide prescription drug coverage to Medicare Part D eligible individuals to disclose to CMS whether the coverage is creditable or non-creditable. For all plan years that end in 2006, the initial Disclosure to CMS Form must be completed on-line no later than March 31, 2006. For all subsequent plan years, the Disclosure to CMS Form must be completed no later than 60 days after the beginning date of their plan year.

In January 2006, CMS issued guidance on the form, manner and timing of providing the Disclosure Notice to CMS. This Disclosure to CMS guidance is posted on the Creditable Coverage web page at http://www.cms.hhs.gov/CreditableCoverage/.

An entity is required to provide the Disclosure Notice through completion of the Disclosure Notice form on the CMS Creditable Coverage Disclosure Web Page at http://www.cms.hhs.gov/apps/ccdisclosure/default.asp unless specifically exempt as outlined in the Disclosure to CMS guidance.

CMS has also posted two documents to assist you. The first document is the Disclosure to CMS Form User Guide which has screen shots of the Disclosure to CMS Form along with an explanation of each required field (this information can also be found in the Disclosure to CMS Guidance paper). The second document is the Disclosure to CMS Commonly Asked Questions and Helpful Hints. This document outlines the commonly asked questions CMS has received as well as some Helpful Hints for Entities completing the Disclosure to CMS form. Both documents can be downloaded from the CMS Creditable Coverage Disclosure to CMS Web Page at http://www.cms.hhs.gov/CreditableCoverage/06_CCDislcosure.asp.

Edwina Rogers
Vice President, Health Policy
The ERISA Industry Committee
1400 L Street, N.W., Suite 350
Washington, DC 20005
(202) 789-1400
Fax (202) 789-1120
e-mail: erogers@eric.org

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