Employers who sponsor group health plans must provide notices of creditable or non-creditable coverage to Medicare-eligible individuals before each year’s Medicare Part D annual enrollment period by October 15th. This notice is meant to educate Medicare beneficiaries of their options by informing them of whether the group health plan is “creditable”, meaning it is expected to cover, on average, as much as the standard Medicare Part D prescription drug plan. The timing is also tied to the Medicare open enrollment period so beneficiaries can compare their group health plan options against their Medicare options.
Some employers will choose to provide the notice to all covered employees while others, generally smaller companies, will distribute the notice to only those who are Medicare eligible. Keep in mind, however, that Medicare eligibility can include people under 65 with disabilities.
If your company has fewer than 100 employees, we advise that you give this notice just to those Medicare eligible employees or dependents who are members of your health plan. If your company has 100 or more employees, we recommend sending the notice to all health plan subscribers. A short cover note explaining why the notice is being sent can help prevent calls from confused recipients.
CMS also requires that employers disclose to CMS within 60 days of the status of the company’s creditable coverage. The disclosure form can be found in the link below.
The link also contains the most current copy of the Model Notice. Please let us know if you have any questions in completing the form or prefer to have a copy of the notice forwarded to you.
Matt Hollister, L.I.A., M.P.H.