Medicare Open Enrollment Begins October 15; New Deadline to Provide Part D Creditable Coverage Disclosures

As a reminder, the Medicare fall Open Enrollment period now begins on October 15 and ends December 7. This means plan sponsors of group health plans (including employers) that provide prescription drug coverage must distribute required creditable coverage disclosure notices to Medicare eligible participants prior to October 15. The Medicare Modernization Act requires entities whose policies include prescription drug coverage to notify Medicare eligible policyholders whether their prescription drug coverage is creditable coverage, which means that the coverage is expected to pay, on average, as much as the standard Medicare prescription drug coverage.

For such an entity, there are two disclosure requirements:

1. A written disclosure notice to all Medicare-eligible individuals annually who are covered under its prescription drug plan, prior to October 15 each year and at various specified times, including when an individual joins the plan. This disclosure must be provided to Medicare-eligible active working individuals and their dependents, Medicare-eligible COBRA individuals and their dependents, Medicare-eligible disabled individuals covered under the prescription drug plan, and any retirees and their dependents.
2. The Online Disclosure to CMS form to report the creditable coverage status of its prescription drug plan. The Disclosure should be completed annually no later than 60 days from the beginning of a plan year, within 30 days after termination of a prescription drug plan, or within 30 days after any change in creditable coverage status.

For further information regarding Medicare Open Enrollment, please click here. You can also visit the HR360 section on Medicare to learn more about the program and the employer notice requirements under Part D (including model notices).

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