October 14 Deadline - Medicare Part D Notice
By Bruce Davis
It's that time of year again when employers must comply with notifying Medicare-eligible members covered under employer-sponsored health plans whether their prescription drug (Rx) benefits qualify as "creditable coverage" under Medicare Part D.
The Medicare Part D Notice is due by October 14, 2016. There have been no changes in the Model Part D Creditable Coverage Notice since last year—thus you can use your 2015 Notice (although you will need to update your 2015 notice with corresponding 2016 dates).
The Notice is intended for Part D-eligible individuals who are covered (or seeking to be covered) for employer-sponsored Rx coverage, including active employees, retirees, and COBRA continuants (and their dependents) who are eligible for Medicare as the result of age or disability. The only exception to providing a Medicare Part D Notice of Creditable Coverage is for those employers who provide Rx coverage through a qualified Employer Group Waiver Plan (EGWP).
Rather than try to identify Medicare-eligible individuals for targeted distribution, many employers simply provide the Notice to all their plan participants. This is the Model Notice for your convenience.
You will recall that in addition to distributing the Medicare Part D Notice, there is a requirement to notify the Centers for Medicare & Medicaid Services (CMS) reporting of whether your coverage is creditable or non-creditable coverage by March 1, 2017 (for calendar year plans).