Medicare Part D Notices
The Medicare Prescription Drug, Improvement, and Modernization Act of 2003 requires group health plan sponsors that provide prescription drug coverage, to annually disclose to individuals eligible for Medicare Part D whether the plan's coverage is creditable or non-creditable. 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 and may cause consequences for employers if an employee does have to pay a higher premium.
Plan sponsors must provide the annual disclosure notice to Medicare-eligible individuals before Oct. 15, 2018—the start date of the annual enrollment period for Medicare Part D. CMS has provided two model notices for employers to use:
These model notices are also available in Spanish on CMS’ website. Plan Sponsors should carefully review and customize these notices to ensure they accurately reflect their plan provisions. Disclosure notices must be provided to all Part D eligible individuals who are covered by, or who apply for, the plan’s prescription drug coverage, regardless of whether the prescription drug coverage is primary or secondary to Medicare Part D. The disclosure notice requirement applies to Medicare beneficiaries who are active or retired employees, disabled or on COBRA, as well as Medicare beneficiaries who are covered as a spouse or dependent. To simplify plan administration, we recommend plan sponsors provide the disclosure notice to ALL plan participants.
For specific questions about this notice, please contact your broker.