Employer Notice Requirements under Medicare Part D (Creditable Coverage) - Capstone Brokerage

By: Grace Taylor, Capstone Brokerage Vice President, October 12, 2016

Notice:

The Deadline to provide your employees this notice is Oct 15th !!!

What is a Medicare Part D Creditable Coverage Notice?

Prior to each year’s Medicare Part D annual enrollment period, employer groups that offer prescription drug coverage must provide notices of creditable or non-creditable coverage to any Medicare eligible individuals.

The required notices may be provided in several ways. Employers can provide them with their annual enrollment materials, mailings or electronically (with the employee’s permission). Employers can use the federal Centers for Medicare & Medicaid Services (CMS) model notices or other notices that meet prescribed standards; however, the notices are required to be distributed no later than Oct. 14, 2016.

Group health plan sponsors that provide prescription drug coverage to Medicare Part D eligible individuals must also release annually to the CMS—generally, no later than March 1—whether their coverage is creditable or non-creditable. The disclosure obligation applies to all plan sponsors that provide prescription drug coverage, even those that do not offer prescription drug coverage to retirees.

What does Creditable Coverage Mean?

Creditable coverage means that the coverage is expected to pay, on average, as much as the standard Medicare prescription drug coverage.

This notice must be provided annually prior to October 15th, and at various other times as required under the law, to the following individuals:

• Medicare-eligible active working individuals and their dependents (including a Medicare-eligible individual when he or she joins the plan);
• Medicare-eligible COBRA individuals and their dependents;
• Medicare-eligible disabled individuals covered under an employer’s prescription drug plan; and
• Any retirees and their dependents.

Model notices are available from the Centers for Medicare & Medicaid Services (CMS). In addition, employers are required to complete an online disclosure to CMS to report the creditable coverage status of their prescription drug plans. This disclosure is also required annually, no later than 60 days from the beginning of a plan year, and at certain other times.

You can visit medicare.gov for more information about how the law affects employer-provided group health plans.

Additional Resources:

Creditable Coverage Landing Page

Creditable/Non-Creditable Model Notices from CMS (English & Spanish)

Plan sponsors should carefully review and customize these model notices to ensure they accurately reflect the plan provisions.

Creditable Coverage Simplified Determination

If you have any questions about Employer notice requirements under Medicare part D please contact your insurance provider or healthcare benefits broker. At Capstone we are happy to guide our clients and help them to comply with the required notices.