Medicare Part D Creditable Coverage Notices for 2025

If your clients offer a prescription drug plan to Medicare-eligible individuals, understand that they must communicate their creditable or non-creditable status to their members. This determination is mandatory at least once per year and the deadline for completion is prior to October 15th.

The Medicare Modernization Act mandates that certain entities offering prescription drug coverage, including employer and union group health plan sponsors, disclose to all Medicare-eligible individuals with prescription drug coverage under the plan whether such coverage is “creditable.” Determining whether or not certain coverage is creditable is essential to an individual’s decision whether to enroll in a Medicare Part D prescription drug plan.

Action Items for Employers / Plan Sponsors

  • Step 1: Determine if the plan is creditable or not & notify your Medicare-eligible employees before 10/15/25.Below are sample notices that can be put on your letterhead to be mailed to your Medicare-eligible members. Simply replace the bracketed sections with the correct company name, plan name, plan specifics, etc. Members should receive their letters from you by October 15, 2025.

Creditable Notice
Non-Creditable Notice

  • Step 2: The second disclosure requirement is for entities to complete the Online Disclosure to CMS Form to report the creditable coverage status of their prescription drug plan. The Disclosure should be completed annually no later than 60 days from the beginning of a plan year (contract year, renewal year), within 30 days after the termination of a prescription drug plan, or within 30 days after any change in creditable coverage status. This requirement does not pertain to the Medicare beneficiaries for whom entities are receiving the Retiree Drug Subsidy (RDS).

Go to the following link and complete the steps.

For more information, please visit the CMS website and this FAQ.

Please utilize the spreadsheet linked below to assist with determining if a plan is creditable or not. The spreadsheet is broken up with tabs by carrier for convenience.

EXCEL SPREADSHEET: Creditable vs. Non-Creditable Medicare Part D Plans 2025

Questions? Contact our Group Admin team at groupadmin@ociservices.com or give us a call us at (402) 330-8700.