Medicare Part D Notice: Action Item by October 15, 2013

The Centers for Medicare and Medicaid (CMS) requires that employers disclose the creditable coverage status of their prescription drug plan to employees and their families who are eligible for Part D Medicare benefits every year.  This notice must be provided for the first time when the employee initially enrolls in the plan and annually thereafter.  This notice provides the employee with important information to assist them in choosing whether to enroll in a Part D plan during the annual Medicare open enrollment period.

The Patient Protection and Affordable Care Act, as modified by the Health Care and Education Reconciliation Act of 2010 (PPACA) changed the Medicare Part D annual coordinated election and enrollment period to October 15th – December 7th.  Thus, notices of creditable and non-creditable coverage to Medicare Part D eligible individuals must now be made prior to October 15th for each subsequent plan year.

Group health plans must disclose to Medicare Part D (prescription drug) eligible individuals whether the group health plan provides creditable or non-creditable coverage. Creditable coverage means that the group health plan’s coverage is at least actuarially equivalent to Medicare Part D prescription drug coverage.

Our firm is providing you with your notice.  Please be advised this notice is the same as past few years and was created for plans after 4/1/2011.

Therefore, there are two requirements you need to be aware of and to act accordingly by OCTOBER 15, 2013:

ACTION ITEM #1

The first disclosure requirement is to provide a written disclosure notice to all Medicare eligible individuals annually who are covered under its prescription drug plan.  This needs to happen prior to October 15th each year and at various times as stated in the regulations, including to a Medicare eligible individual when he/she joins the plan.

This disclosure must be provided to:

• Medicare eligible active working individuals and their dependents
• Medicare eligible COBRA individuals and their dependents
• Medicare eligible disabled individuals covered under your prescription drug plan
• Any retirees and their dependents.  The MMA imposes a late enrollment penalty on individuals who do not maintain creditable coverage for a period of 63 days or longer following their initial enrollment period for the Medicare prescription drug benefit.   This information is essential to an individual’s decision whether to enroll in a Medicare Part D prescription drug plan.

MEA/Trinity Benefit Advisors is providing this NOTICE here: Model Creditable Coverage Disclosure Notice For Use After April 1 2011 (2013).

This notice should be provided to all enrolled employees under your group plan.

ACTION ITEM # 2

The second disclosure requirement is for entities to complete the Online Disclosure to the Center for Medicare & Medicaid Services (CMS) to report the creditable coverage status of their prescription drug plan. The Disclosure should be completed annually no later than 60 days from the beginning of a plan year (contract year, renewal year), within 30 days after termination of a prescription drug plan, or within 30 days after any change in creditable coverage status.

This is the link to complete the disclosure:  https://www.cms.gov/Medicare/Prescription-Drug-Coverage/CreditableCoverage/CCDisclosureForm.html

Please contact us with any questions.

*This Alert was provided by MEA in partnership with Trinity Benefits Advisors.  MEA and Trinity Benefits Advisors are dedicated to providing timely and accurate advice and resources as Members seek to develop competitive and compliant employee benefits programs.  This MEA Member Alert is provided for general informational purposes only and does not constitute legal advice.

 
[author] [author_image timthumb=’on’]https://meainfo.org/app/uploads/2014/10/leslie-barringer.jpg[/author_image] [author_info]Leslie Barringer
Director of Compensation & Benefitslbarringer@meainfo.org[/author_info] [/author]