October 31, 2006
Annual Medicare Part D Creditable Coverage Notice
Medicare Part D requires sponsors of group health plans offering prescription drug coverage to provide notices of creditable or non-creditable coverage to all active employees, retirees, and dependents participating in the plan who are eligible for Medicare Part D. These notices must be provided at various times, including, but not limited to, on an annual basis prior to the annual Medicare Part D open enrollment period that begins on November 15th of each year.
Note: If an employer provides the required annual notice to all participants of the plan (i.e., not just those who are Medicare eligible), then the employer will not need to provide a separate notice prior to an individual’s initial enrollment period.
If you sponsor a group health plan covering individuals who are Medicare eligible, you must provide a new notice of creditable or non-creditable coverage by November 15th. The Centers for Medicare and Medicaid Services (CMS) has recently posted new model notices, which are available at:
https://www.cms.hhs.gov/CreditableCoverage/90_ArchivesCC.asp#TopOfPage.
Depending on the nature of your plan (e.g., you aggregate your major medical with a reimbursement plan such as an HRA), you may need to customize the model notices before using them.
If we can assist with the preparation of the notice, please contact us.