Benefits & Medicare Part D

Creditable Coverage Disclosure to CMS and Medicare-Eligible Individuals

The two disclosure duties plan sponsors should track: notices to Medicare-eligible individuals and annual reporting to CMS.

Last reviewed: August 21, 2026United States · FederalPrimary-source reviewed

What creditable coverage means

Prescription drug coverage is creditable when it is expected to pay, on average, at least as much as standard Medicare Part D coverage. Individuals need this information because a continuous gap of 63 days or more without Part D or other creditable coverage may lead to a late-enrollment penalty.

Notice to Medicare-eligible individuals

Entities offering prescription drug coverage generally must disclose whether the coverage is creditable or non-creditable to Medicare-eligible active employees, dependents, COBRA participants, retirees, and other covered individuals. The annual notice is due before October 15 and is also required at specified enrollment, status-change, and request events.

Disclosure to CMS

Within 60 daysAfter the beginning of the plan, contract, or renewal year.
Within 30 daysAfter plan termination or a change in creditable-coverage status.

Control checklist

  • Determine creditable status for each prescription drug option annually.
  • Identify all potentially Medicare-eligible covered individuals.
  • Use a compliant notice with all required data elements.
  • Retain delivery evidence and the CMS submission confirmation.
  • Coordinate changes with carriers, actuaries, brokers, and COBRA administrators.

Primary sources

This resource is provided for general educational purposes and does not constitute legal, tax, benefits, or other professional advice. Requirements vary by organization and jurisdiction. Confirm current rules with authoritative sources and qualified advisors.

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