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Compliance Corner: Reminder- Medicare Part D Creditable Coverage Deadlines

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Employers who sponsor a group health plan must disclose whether the plan's prescription drug coverage is creditable or not, based on Medicare Part D coverage.  Your carrier/TPA/PBM should provide you with a determination of creditable coverage status to use for tailoring the appropriate disclosures to the Centers for Medicare & Medicaid Services (CMS) and to Part D eligible individuals who are covered under, or who apply for, the health plan.

 

1.  Disclosure to CMS of a plan’s creditable coverage status must be made by the employer annually within 60 days after the beginning of the plan year (i.e., renewal, contract year, etc.) and if/when changes to creditable coverage occur mid-plan year.  Disclosures are made online at CMS.gov.  For health plans that began January 1, 2016, the employer must submit disclosure no later than February 29, 2016.  Also, for health plans with non-calendar plan years, disclosure is due within 60 days from the beginning of the plan year.  For example, plans beginning on February 1, 2016 must disclose to CMS by March 31, 2016.  CMS provides line-by-line instructions, as well as, commonly asked questions and helpful hints; see links below.

2.  Notice to Part D Eligible Individuals must be distributed by October 14th of each year, as well as, mid-year based on certain trigger events; see summaries below for additional requirements. These individuals may include active employees, employees on leave, retirees, as well as their dependents, and COBRA continuants.  Best practice is to provide the notice in the new hire packet with enrollment materials and the annual open enrollment packet if it is provided by October 14th; otherwise separately to meet the deadline. It is important to track and document distribution of required notices, should you be asked to provide proof of disclosure during an audit for example.

View CMS website for model notices and to make annual online disclosure to CMS
View Line-by-Line Instructions, including screen shots, for disclosure to CMS
View CAQ & Helpful Tips for disclosure to CMS
View summary on CMS disclosure
View summary on notice requirements

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