Each year, Medicare Part D requires group health plan
sponsors to disclose to individuals who are eligible for Medicare Part D and to
the Centers for Medicare and Medicaid Services (CMS) whether the health plan’s
prescription drug coverage is creditable. Plan sponsors must provide the annual
disclosure notice to Medicare-eligible individuals before Oct. 15, 2019.
What is this notice?
This notice is important because Medicare beneficiaries who
are not covered by creditable prescription drug coverage and do not enroll in
Medicare Part D when first eligible will likely pay higher premiums if they
enroll at a later date. Although there are no specific penalties associated
with this notice requirement, failing to provide the notice may be detrimental
to employees.
What do employers need to do?
Employers should confirm whether their health plans’
prescription drug coverage is creditable or non-creditable and prepare to send
their Medicare Part D disclosure notices before Oct. 15, 2019. To make the
process easier, employers often include Medicare Part D notices in open
enrollment packets.
Resources
CMS has provided model
disclosure notices for employers to use. Employers are not required to use the
model notices from CMS. However, if the model language is not used, a plan
sponsor’s notices must include certain information, including a disclosure
about whether the plan’s coverage is creditable and explanations of the meaning
of creditable coverage and why creditable coverage is important.
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