Progressive Benefit Group would like to remind you that on an annual basis, Medicare Part D requires employers to disclose to individuals who are eligible for Medicare Part D and to the Centers for Medicare and Medicaid Services (CMS) whether the health plan’s prescription drug coverage is creditable.

Plan sponsors must provide the annual notice to eligible individuals before October 15, 2019 – the start date of the annual enrollment period for Medicare Part D.

This notice is important because Medicare beneficiaries who are not covered by creditable prescription drug coverage and who choose not to enroll in Medicare Part D when first eligible will likely pay higher premiums if they enroll at a later date. Thus, although there are no specific penalties associated with this notice requirement, failing to provide the notice may trigger adverse employee relations issues.

Employers should confirm whether their health plan’s prescription drug coverage is creditable or non-creditable and prepare to send their Medicare Part D disclosure notices by Oct. 14, 2019.

To make the process easier, employers who send out open enrollment packets prior to Oct. 15 often include the Medicare Part D notices in these packets. The notice must also be distributed at other times, such as when creditable coverage status changes or when a Medicare-eligible employee first joins the plan. As a client of Progressive Benefit Group, if we have prepared your benefit guide/booklet, this notice is included and therefore the requirement has been satisfied.

The Center for Medicare & Medicaid Services has provided model disclosure notices for employers to use.