Creditable coverage means that the prescription drug coverage under the group health plan equals or exceeds the value of the standard prescription drug coverage under Medicare Part D based on actuarial value. There are two ways in which a plan can determine whether the coverage provided is creditable or non-creditable. There is the Creditable Coverage Simplified Determination and the use of an Actuarial to make the determination. Guidance on using the Creditable Coverage Simplified Determination can be found on the CMS website. However, the insurance carrier usually provides confirmation on whether the plan is Part D creditable or not. If the company has more than one plan and the plans differ in whether they offer creditable or non-creditable prescription drug coverage, different notices must be distributed for each plan.
Completing the form is a relatively simple process. It is a four-page document. It is noted where to add company information and plan information. CMS has posted model notices on their website. A company is not required to use the model notices but must include specific information if creating their own disclosure.