Healthcare Reform Updates

Medicare Part D Notice Due Before October 15

In preparation for the Medicare fall open enrollment period, employers sponsoring group health plans that include prescription drug coverage are required to notify all Medicare-eligible individuals whether such coverage is creditable (i.e., that the coverage is expected to pay, on average, as much as the standard Medicare prescription drug coverage).

Written Disclosure to Individuals
This written disclosure notice must be provided annually, prior to October 15, and at various other times as required under the law, to the following individuals:

  • Medicare-eligible active working individuals and their dependents;
  • Medicare-eligible COBRA individuals and their dependents;
  • Medicare-eligible disabled individuals covered under an employer's prescription drug plan; and
  • Any retirees and their dependents.

Model notices are available from the Centers for Medicare & Medicaid Services (CMS).

Online Disclosure to CMS Also Required
Additionally, employers are required to complete an online disclosure to CMS to report the creditable coverage status of their prescription drug plans. This disclosure is also required annually, no later than 60 days from the beginning of a plan year, and at certain other times.

Visit our section on Medicare for more information about how the law affects employer-provided group health plans.

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