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Question: If one of my clients has a company that has a subsidiary, but a single medical plan that covers both the primary and subsidiary company, should the CMS online disclosure of Creditable Coverage for Medicare be filled out for each company separately?

Our Response: In accordance with the Creditable Coverage Disclosure to CMS Form Instructions and Screen Shots (PDF, 225KB) [PDF, 224KB] , the entities can file based upon Federal Tax Identification Number – either combined or separately.  According to the CMS, “for entities that have multiple subsidiaries (divisions, line of businesses, operating units, control groups, etc.) that are all covered under the same type of coverage, the Federal Tax Identification Number (also known as the Employer Identification Number, or EIN) for the Parent Company may be used when completing the entity’s EIN information for the entire company. If the form is completed separately for individual subsidiaries (divisions, line of businesses, operating units, control groups, etc.), the EIN for each subsidiary should be provided.”