Medicare Part D | Creditable Coverage Disclosure Notices
June 8, 2017
Disclosure to Individuals
Group health plans that provide prescription drug benefits are required to provide Medicare Part D Notices. Depending on the plan’s design, it will be necessary to issue either a “Notice of Creditable Coverage” or a “Notice of Non-Creditable Coverage.”
Notices must be provided:
- Annually to eligible individuals;
- Prior to an individual’s initial Medicare Part D enrollment period;
- In the initial benefit materials provided to all newly benefit-eligible individuals;
- Whenever the coverage changes between creditable and non-creditable or coverage is no longer offered; and
- At the request of a beneficiary
Plan sponsors must provide creditable coverage disclosure notices each year before October 15 – the start date of the annual enrollment period for Medicare Part D. A common practice is for employers to provide this notice to each new plan enrollee and then annually after that (prior to the Medicare annual Part D enrollment period).
Disclosure to CMS
- Plan sponsors are also required to disclose to CMS whether their prescription drug coverage is creditable or non-creditable.
- The notification to CMS must be made on an annual basis, no later than 60 days from the beginning of a plan year. It also must be provided within 30 days after termination of a prescription drug plan and within 30 days after any change that affects whether the coverage is creditable.
- Plan sponsors are required to use CMS’ online disclosure form.