MEDICARE PART D CREDITABLE COVERAGE NOTICE ANNUAL DEADLINE NOW A MONTH EARLIER
September 16, 2011
Employers that currently provide prescription drug coverage must disclose to plan participants who are eligible for Medicare Part D whether the prescription drug coverage provided under the group health plan is creditable or non-creditable.
The Patient Protection and Affordable Care Act (PPACA) changed the Medicare Part D annual enrollment period to October 15 through December 7 of each year, thus changing the date by which notices must be distributed. Beginning in 2011, employers should send required Medicare Part D notices by October 15. Previously, this deadline was November 15.
Since it is often difficult for employers to identify all individuals (including dependents) who may be eligible for Medicare, many employers satisfy this requirement by including the notice in enrollment materials or in separate mailings provided to all employees who participate in the employer-sponsored plan.
In addition to the annual notification, there are also other times that employers are required to provide this notice. Below is a list of times at which notice of creditable or non-creditable coverage is required:
- Prior to an individual's initial enrollment period for Part D,
- Prior to the effective date of coverage for any Medicare-eligible individual that joins your plan,
- Whenever prescription drug coverage ends or changes so that it is no longer creditable or becomes creditable, or
- Upon the request of the individual.
Many insurance carriers already send the notice annually to all participants, so employers should first check with their insurer to determine if a notice is already being provided to their employees. Employers are not required to provide their own notice if participants receive a compliant notice from the insurance company or the employer’s claims administrator.
CMS has also posted updated model disclosure notices that reflect the new enrollment period. The model notices can be found at http://www.cms.gov/CreditableCoverage.





