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 their health plan’s prescription drug coverage is creditable. Plan sponsors must provide the annual disclosure notice to Medicare-eligible individuals before Oct. 15, 2016—the start date of the annual enrollment period for Medicare Part D.
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 by Oct. 14, 2016. CMS also requires notices to be provided to "Medicare eligible plan participants" at other times during the year, such as:
- Prior to an affected individual's initial enrollment period for Part D
- Prior to the effective date of coverage for any Medicare-eligible individual who joins the plan
- Whenever prescription drug coverage ends or changes, which results in a change in the status of the coverage
- Upon an affected individual's request
Model notices (in English and Spanish), and additional guidance on this compliance matter can be found at https://www.cms.gov/Medicare/Prescription-Drug-Coverage/CreditableCoverage/Model-Notice-Letters.html