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Reminder: Medicare Part D Notices Due Oct. 15 and March 1
Employers whose provide Rx drug benefits must notify Medicare-eligible employees and CMS

By Stephen Miller, CEBS  8/1/2014
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Employers whose health care plans include prescription drug benefits for active employees (or retirees) who are Medicare-eligible must notify those covered individuals by Oct. 15 of each year whether their drug benefit is "creditable coverage," meaning that it is expected to cover, on average, as much as the standard Medicare Part D prescription drug plan. These plan sponsors must also report whether their drug benefit is creditable coverage to the federal Centers for Medicare & Medicaid Services (CMS) by March 1 for calendar-year plans.

The disclosure obligation applies to all plan sponsors that provide prescription drug coverage, even those that do not offer prescription drug coverage to retirees. Medicare Part D, which became effective in 2006, is a federal program to subsidize the cost of private prescription drug plans.

Oct. 15 Notification to Part D-eligible Individuals

The CMS requires that companies provide the notice before the annual Medicare Part D election period, Oct. 15 to Dec. 7 each year for coverage beginning Jan. 1.The CMS Creditable Coverage website provides complete text of the guidance and sample disclosure notices. Plan sponsors should carefully review and customize these notices to ensure they accurately reflect their plan provisions.

The creditable-coverage notice must be given to all Part D-eligible individuals who are covered under, or apply for, an employer's prescription drug benefits plan. This requirement applies to Medicare beneficiaries who are active employees and those who are retired, as well as Medicare beneficiaries who are covered as spouses under active or retiree coverage.

CMS also requires plan sponsors to provide notice of their creditable-coverage status to Part D-eligible members at other times, including:

Before an individual’s initial opportunity to enroll in Part D (generally satisfied by the requirement to provide notice annually to all Medicare- eligible employees prior to Oct. 15).

Before the effective date of coverage for any Medicare-eligible individual that joins the employer's plan.

When the plan's prescription drug coverage ends or its creditable coverage status changes.

Upon an individual's request.

March 1 Disclosure to CMS

As part of the disclosure requirements under Medicare Part D, employer-sponsored group health plans that offer prescription drug coverage to Part D-eligible individuals are required to submit an electronic disclosure notice to the CMS on an annual basis, reporting whether that coverage is creditable or non-creditable.

A plan sponsor must submit a new disclosure to CMS no later than 60 days after the beginning of each plan year—i.e., by March 1, 2015 for calendar year plans.

This requirement applies not only to employer-sponsored retiree health plans but to employer-sponsored plans extended to active employees and their covered spouses who are enrolled or are Medicare-eligible (generally speaking, age 65 or over).

A plan sponsor is required to provide the disclosure notice through completion of the Creditable Coverage Disclosure Form on the CMS Creditable Coverage Disclosure web page. This is the sole method for complying with the CMS disclosure requirement.

Stephen Miller, CEBS, is an online editor/manager for SHRM. Follow him on Twitter @SHRMsmiller.

Related SHRM Articles:

Medicare Part D 'Creditable Coverage' Disclosures Due [to CMS] March 1, SHRM Online Benefits, February 2014

Helping Those Turning 65 to Navigate Medicare, SHRM Online Benefits, July 2013

Related External Articles:

It’s That Time Yet Again—Creditable Coverage Disclosures to CMS Due by March 1, Buck Consultants, , Buck Consultants, February 2015

Deadline Nears for Submission of Creditable Coverages Disclosures to CMS, Marsh Consulting Group, February 2015

Medicare Part D creditable/non-creditable coverage notices due before October 15, Buck Consultants, September 2013

Changes to Medicare Part D Plan Parameters for 2014, McGraw Wentworth, May 2013

2014 Medicare Part D Amounts Will Be Lower than 2013 Amounts, Segal Consulting, April 2013

CMS Releases 2014 Medicare Part D Benefit Parameters, Buck Consultants, Apr 2013

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