ACA Filing and Medicare Creditable Coverage Deadlines Approaching

By Higginbotham on February 20 , 2018


This is our final reminder (until next year) of the due dates for IRS reporting under the ACA. Filing the 2017 Forms 1094-B, 1095-B, 1094-C and 1095-C with the IRS must be completed no later than Feb. 28, 2018, if not filing electronically, or Apr. 2, 2018, if filing electronically. Furthermore, employee statements required under the ACA are due no later than Mar. 2, 2018. For the 2017 reports due in 2018, there will be no further extensions of these deadlines. The 30-day extension to furnish these reports that may be granted in a “normal” year will not be granted this year, as the extensions that the IRS previously granted are more generous. Additionally, the IRS has carried over the “good faith effort” transition relief granted last year.

Please also remember that entities that provide prescription drug coverage to Medicare Part D eligible individuals must disclose to the Centers for Medicare and Medicaid Services (CMS) if the coverage is "creditable prescription drug coverage" regardless of whether the entities' coverage is primary or secondary to Medicare. Entities must disclose creditable coverage status to CMS using the online Disclosure to CMS Form. 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 termination of a prescription drug plan or within 30 days after any change in creditable coverage status. Therefore, sponsors of calendar year plans must submit these disclosures by Mar. 1, 2018. Sponsors of non-calendar year plans should mark their calendars to make sure the disclosure to CMS is made within 60 days after the beginning of the plan year (e.g., for an April 1 plan year, the CMS online disclosure should be made no later than May 30). An entity that does not offer outpatient prescription drug benefits to any Part D-eligible individual on the first day of its plan year is not required to complete the CMS disclosure form for that plan year.

For guidance on Creditable Coverage Disclosure to CMS, you may refer to the document below or the CMS website. Contact your Higginbotham representative if you need assistance or have any further questions.

Additional information can be found in this legislative guide:
Medicare Part D Disclosures due by March 1, 2018 for Calendar Year Plans


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