September 24, 2025

Annual required creditable coverage notices

Employers are required to take action and meet two separate and distinct annual creditable coverage disclosure requirements:

  1. Annual notice to Medicare eligible individuals
  2. Online disclosure to CMS Form

Please note: The information contained in this business bulletin is not intended to be, nor should it be construed as, legal advice. For specific information regarding your organization and the Medicare Prescription Drug, Improvement, and Modernization Act (MMA) contact your benefits consultant and/or legal counsel.


1. Annual notice to Medicare eligible individuals

The Medicare Prescription Drug Improvement and Modernization Act (MMA) requires plan sponsors disclose to all Medicare-eligible individuals the creditable or non-creditable coverage status of their current prescription drug benefits prior to Oct. 15 each year and at other times as outlined under §423.56 of the final MMA regulation. Most employers choose to notify all plan participants annually as part of open enrollment or by including the disclosure in a payroll notice.

We are happy to say MESSA’s actuaries, Willis Towers Watson, have reviewed our prescription drug coverage and determined that MESSA’s prescription drug benefits are creditable. Creditable coverage means the prescription drug benefit under the employer’s plan is equal to or better than Medicare Part D coverage.

Each year MESSA receives questions regarding the completion of the disclosure notice. For your convenience, we have provided a model creditable coverage notice in fillable Word format. Highlighted in red are the areas you need to either update or delete before distributing this notice. Note: The disclosure notice has not changed, you may use the notice you sent last year.

For more information about this notice requirement refer to the disclosure of creditable coverage to Medicare Part D eligible individuals guidance provided by the Center for Medicare & Medicaid Services.


2. Disclosure to CMS Form

Each year plan sponsors are required to report to the Center for Medicare & Medicaid Services the creditable coverage status of their prescription drug plan. Employers must go online and complete the Disclosure to CMS Form no later than 60 days after the beginning of your plan year, which starts Jan. 1. Mark your calendar to complete this online form before Mar. 2.

Click here to access the Online Disclosure to CMS form.
Click here to view helpful hints for completing this form.

For more information about this notice requirement refer to the creditable coverage disclosure to CMS guidance provided by the Center for Medicare & Medicaid Services.


Questions about your MESSA benefits? Call MESSA Group Services at 888-888-4167