Every year groups are required to notify anyone that is Medicare-eligible regarding if the prescription plan they provide meets Medicare Creditable Coverage requirements.
Language from the notification memo from CMS is below.
Notification needs to go to Medicare eligible members by October 15th. Additionally, you must go the CMS site each year and report on your plan. Use the link below for more information and helpful links.
- Medicare Part D Creditable Coverage Disclosure Notice
- Medicare Part D Non-Creditable Coverage Disclosure Notice
Here is the CMS notice in part:
Reminder – Medicare Part D Employer Notification Requirements
Update 09/22/17: The Medicare and You 2018 handbook is now available.
The 2018 Annual Election Period (AEP) for Medicare Part D begins October 15, 2017 and ends December 7, 2017.
The Medicare Modernization Act of 2006 provides access to prescription drug coverage to all Medicare-eligible persons under Medicare Part D. Plan sponsor notice regarding the organization’s prescription benefits must be provided to any Medicare-eligible person whether due to age or disability and is required for employees, spouses, dependents, those on Federal COBRA or New York, New Jersey, Pennsylvania, and Delaware continuation including retirees. Notice must be provided before Open Enrollment begins.
Employees will use that information to help them formulate their personal decision of whether or not they will enroll in Medicare Part D prescription coverage outside of the employer plan. This decision is critical as penalties apply when Part D is not timely in place.
Medical insurance carriers typically notify policyholders regarding the Creditable versus Non-Creditable status of the prescription coverage plan. It is the plan sponsors’ (typically the employer) responsibility to notify their groups’ members.
Please keep in mind that this determination is the employer’s responsibility when the employer is the plan sponsor. If the carrier states that the health plan is non-creditable, the benefits may still be creditable if the employer has an HRA arrangement. The employer would have to override the carrier notice. Therefore, it is the employer’s responsibility to examine all of the benefits that the employer is providing and determine the creditability of the prescription coverage. The carrier is only providing notification regarding the creditability of the coverage that the carrier provides.