In preparation for the Medicare fall open enrollment period, employers sponsoring group health plans that include prescription drug coverage are required to notify all Medicare-eligible individuals whether such coverage is creditable. Creditable coverage means the coverage is expected to pay, on average, as much as the standard Medicare prescription drug coverage.

Many employers satisfy this requirement by including the notice in enrollment materials or in a separate mailing. As a reminder, the Affordable Care Act (ACA) changed the Medicare Part D annual enrollment period to October 15 through December 7.

The written notice must be provided annually, prior to October 15th, and at various other times as required under the law, to the following individuals:

  •   Medicare-eligible active working individuals and their dependents;
  •   Medicare-eligible COBRA individuals and their dependents;
  •   Medicare-eligible disabled individuals covered under an employer’s prescription drug plan; and
  •   Any retirees and their dependents covered under an employer’s prescription drug plan

Because it may be difficult to identify all Medicare Part

D participants in the group health plan, it may be prudent to provide the disclosure to all plan participants annually, prior to October 15th as well as to all new hires prior to initial enrollment in the group health plan.

Model Notice Available

If you would like to receive a sample Creditable Coverage Model Notice that you can customize, please contact Lucia Fan, lucia@the-dgroup.com

Model Notices in English and Spanish (available in PDFs only) are also available from the Centers for Medicare and Medicaid Services (CMA).

Notices can be electronically distributed. Regulations permit electronic distribution to participants “who have the ability to access electronic documents at their regular place of work as a part of their work du5es.”

Additionally, employers are required to complete an online disclosure to CMS to report the creditable coverage status of their prescription drug plans.

This disclosure is required annually, no later than 60 days from the beginning of a plan year, and at certain other 5mes.