Medicare Part D Creditable Coverage Disclosure Due Before October 15th

Tuesday, October 10, 2017

Medicare Part D Creditable Coverage Disclosure Due Before October 15th

In preparation for the fall Medicare open enrollment period, employers with group health plans that include prescription drug coverage must notify all Medicare Part D eligible employees whether such coverage is creditable.  Prescription drug plans are considered "creditable" when they meet or exceed the Standard Medicare Part D Prescription Drug plan coverage.  The written disclosure notice must be provided annually, prior to October 15, 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 employer notices are available from the Centers for Medicare & Medicaid Services (CMS):  

While there are no specific penalties for employers that fail to comply with the Medicare Part D disclosure (except for employers that are claiming the Retiree Drug Subsidy), not providing creditable coverage disclosure notices could lead to employee relations and human resource issues down the road.    

In addition to the employee disclosure, employers must also disclose to CMS whether the coverage offered is creditable.  This disclosure is required whether the entity's coverage is primary or secondary to Medicare.  Employers must disclose creditable coverage status to CMS using the online Disclosure to CMS Form which can be found on the CMS website.  Information about the CMS disclosure can be found here: 

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