• Reminder: Group Health Plans Must Provide Medicare Part D Notices Prior to November 15
  • September 26, 2008
  • Law Firm: Parker Poe Adams & Bernstein LLP - Charlotte Office
  • Prior to November 15th of each year, employers that provide prescription drug coverage must distribute to active and retired covered individuals who are Medicare-eligible a notice disclosing whether the coverage is Medicare Part D “creditable coverage” so that they will have relevant information on whether and when to enroll in a Part D plan. Besides the November 15th notices, employers must also provide notices:

    (a) prior to the effective date of an individual enrolling in the plan and upon any change that affects whether the coverage is creditable prescription drug coverage;

    (b) prior to an individual’s initial enrollment period for the Medicare prescription drug benefit; and

    (c) upon beneficiary request.

    The Centers for Medicare and Medicaid Services (“CMS”) provide model notices, which were recently updated for use after June 15, 2008.  These, along with extended guidance on creditable coverage disclosure can be found at the CMS website. Employers should coordinate with their insurers and third party administrators to ensure that the notice requirement is satisfied.