Medicare D Credible Coverage Notices Due by October 15th

dg-medicare-partd-blogThe Medicare Prescription Drug Improvement and Modernization Act of 2003 implemented prescription drug coverage under Medicare (Medicare D), requiring all employers that offer prescription drug benefits to provide an annual notice of Medicare open enrollment. The notice must go to all Medicare eligible plan participants and qualified beneficiaries before October 15th each year. The notice requirement applies to all employers offering prescription drug benefits regardless of size, whether fully-insured or self-funded, or regardless of ACA grandfathered status. Notification must go to all Medicare eligible plan participants, including active employees and their dependents, retirees and COBRA participants. For most employers, it is easier to issue the notice to all participants as a blanket notice than to identify Medicare eligible employees.

The notice requires that the plan sponsor first determine if their plan offers creditable coverage (meaning it is on average at least as comprehensive as Medicare D coverage), or non-creditable. The Centers for Medicare and Medicaid Services (CMS) provides a simple process to determine whether prescription drug coverage is creditable or not. Once that determination is made, CMS provides model notices to send to participants in both English and Spanish. Notices may be sent separately, included as part of open enrollment or other benefit related materials, or electronically as long as the DOL’s rules on electronic delivery are followed.

Additionally, all plan sponsors are required to notify CMS within 60 days of the start of each plan year as to whether or not their prescription drug plan is creditable or not creditable. This notification is done online at CMS here.

For Diversified Group clients who have elected to have Diversified Group handle your Medicare D notices, DG will determine if the plan is considered creditable or not and will then send the notice either to the client or directly to the plan participant depending upon which service was elected.

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Medicare Part D Notice Deadline: October 14th

dg-medicare-partd-blogAs you may recall, with the introduction of Medicare Part D prescription drug benefits, the Centers for Medicare and Medicaid Services (CMS) imposed specific notice requirements on employers.

Each year, employers whose healthcare plans include prescription drug benefits are required to notify all Medicare beneficiaries and the CMS of the “creditable” or “non-creditable” coverage status of their prescription drug plan. This notice is due on October 14th, before the open enrollment period begins. (Medicare Part D Open Enrollment is October 15th – December 7th).

Onus on the Employer
Not all carriers are providing notices to their potential Medicare-eligible participants, even if they have assisted in this process in the past. Most carriers are only sending the notice to those individuals they know are already covered by Medicare. Diversified Group recommends you send the notice to all plan participants to ensure that all participants, including spouses and dependents that need the notice, will receive it.

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.

Helping Diversified Group Clients Comply

If your health benefits plan is administered by Diversified Group, you have been informed of the requirements related to Medicare Part D Notices AND the steps we can take to help your plan comply with all Medicare related communication. If you have questions regarding Medicare Part D Notices, please contact your Diversified Group representative at your convenience.

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