Reporting Deadline Approaching

September 21, 2015

Employee Benefit & HR News

The Centers for Medicare and Medicaid Services (CMS) requires you to notify Medicare Part D Eligible members if the drug coverage offered by the employer is Creditable or Non Creditable by no later than October 15th of every year and annually notify CMS, online within 60 days after the first day of the plan year of the coverage status.

REQUIREMENTS 

Provide notice to Medicare eligible individuals whether the plans prescription drug coverage is creditable or not creditable. Most insurance carriers or Pharmacy Benefit Managers (PBM’s) are providing notices to employers as to whether the coverage is Creditable or Non Creditable. If you did not receive a notice from the carrier you can call and ask them. Although you are only required to provide this notice to Medicare eligible participants we recommend you provide this notice to all employees in the event an employee has a spouse or dependent who is Medicare eligible that you may not be aware of. CMS provides detailed guidance and model notices on their website.

Provide notice to Centers for Medicare and Medicaid Services (CMS) of employer program status. The online disclosure form can be found on the CMS website .

DISCLOSURE OPTIONS

When providing notices to Medicare eligible individuals a number of options are allowed as follows:

  1. Provide the model notice “As Is” subject to completion of certain blanks.
  2. Prepare a customized notice – an employer with or without creditable coverage can provide a customized creditable coverage notice, provided that it meets CMS’s content standards, summarized below.

If coverage is creditable, customized disclosure notices must address the following items:

  • that the employer has determined that the prescription drug coverage is creditable ;
  • the meaning of creditable coverage , as defined by the guidance; and
  • Why creditable coverage is important and that the individual could be subject to payment of higher Part D premiums if he or she subsequently has a break in creditable coverage of 63 days or longer before enrolling in a Part D plan.

If the coverage is non-creditable, customized disclosure notices to Part D eligible individuals must address the following items:

  • that the employer has determined that the prescription drug coverage is not creditable ;
  • the meaning of creditable coverage , as defined by the guidance;
  • that an individual generally may only enroll in a Part D plan from October 15 through December 7 of each year, starting with the 2012 plan year; and
  • an explanation of why creditable coverage is important and that the individual may be subject to payment of higher Part D premiums if he or she fails to enroll in a Part D plan when first eligible.
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About Christopher Johnson

Christopher manages the consulting services department of J.W.Terrill providing regulatory, analytical, technical and wellness support to clients.

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