June 5, 2019

REMINDER: Medicare Part D—Prescription Drug Coverage Notices

On an annual basis, The Centers for Medicare and Medicaid Services (CMS) require all employers who provide a group health plan to their employees to disclose whether the plan has creditable drug coverage under Medicare Part D. Employers must notify CMS and all Medicare eligible participants in the health plan of the plan’s drug coverage status. Individuals are Medicare eligible if entitled to Medicare A and/or enrolled in Part B.

Creditable prescription drug coverage is coverage that is expected to pay at least as much as Medicare’s standard prescription drug coverage. A drug plan is creditable if it:

  1. Provides coverage for brand and generic prescriptions
  2. Provides reasonable access to retail pharmacies
  3. Designed to pay on average at least 60% of participants’ prescription drug expenses

People who have this kind of coverage when they become eligible for Medicare can generally keep that coverage without paying a penalty if they decide to enroll in Medicare prescription drug coverage later. If you have any questions as to whether your drug coverage is creditable, go to www.cms.gov/creditablecoverage then Downloads – Creditable Coverage Simplified Determination.

Required Creditable Coverage Disclosures to CMS and to Eligible Employees

Medicare Part D imposes two annual notice requirements on employers who offer group health plan coverage with a prescription drug benefit:

  1. An online notification to CMS (Centers for Medicare and Medicaid Services) is due 60 days after your plan renewal. For example, if your plan year renews May 1st, you will need to complete the CMS notice by June 29th.  Whether the coverage is creditable prescription drug coverage – This disclosure is required whether the employer’s coverage is primary or secondary to Medicare. Go to www.cms.gov/creditablecoverage and use the online Disclosure to CMS Form.
  2. Notice to Medicare Part D eligible employees whether the coverage is creditable or non-creditable – The employer is required to send participants a Notice of Creditable Coverage (or a Notice of Non-Creditable Coverage) by at least October 15, 2019 or prior to the beginning of your plan year. NOTE: The Fedeli Group will send out an email reminder in September with instructions for you to complete the Medicare Part D notice. 

Employers who contract with Medicare directly as a Part D plan or that contract with a Part D plan to provide qualified prescription drug coverage are exempt from the disclosure requirement.

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