Employers that offer a health plan that covers prescription drugs must provide an annual Medicare Part D notice to anyone who is Medicare eligible. Because an employer might not know if a dependent is Medicare eligible or not, most employers provide this notice to all benefit-eligible employees.
There are five times that creditable coverage determinations must be provided to Part D eligible beneficiaries:
- Prior to the Medicare Part D Annual Coordinated Election Period, which beings on October 15 and runs through December 7th of each year;
- Prior to an individual’s Initial Enrollment Period for Part D;
- Prior to the effective date of coverage for any Medicare-eligible individual that joins the plan;
- Whenever the entity no longer offers prescription drug coverage or changes the coverage offered so that it is no longer creditable or becomes creditable; and
- Upon request by the individual.
If the creditable coverage disclosure notice is provided to all plan participants annually, prior to October 15th of each year, CMS will consider items 1 and 2 to be met.
For more information on this notice requirement, including links to downloadable model notices, click here.