Annual Creditable Coverage Notice Deadline Approaches

September 21, 2018

Employee Benefit & HR News

The annual deadline for the Creditable Coverage notice is arriving once again. The Centers for Medicare and Medicaid Services (CMS) requires employers offering prescription drug coverage to disclose to all Medicare Part D eligible individuals the creditable status of their plan by October 15th each year. Employers may use the model notices available here on CMS’s website.

It can be very difficult for employers to know exactly who should receive the notice as there are ways to become Part D eligible beyond attaining age 65. Many employers resolve this issue by including the notice in enrollment materials or providing separate mailings to all employees who participate in the employer-sponsored plan. We’ve previously discussed distributing the notice here.

If mailing the notice, first-class mail is generally preferred. A single notice may be sent to Part D eligible employees and their Part D eligible spouse or dependents. If the employer is aware a spouse or dependent resides at a different address, a separate notice must be sent to their address. When including with enrollment materials, the notice must be:

  • Prominently referenced; and
  • In a (minimum) 14-point font in a separate box, bolded or offset on the first page.
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About Andie Schieler

Andie is an attorney and works in J.W.Terrill's Compliance division specializing in interpreting the Affordable Care Act and various insurance laws. She advises clients on legal and regulatory issues affecting their employee benefit plans. She obtained her law degree from Saint Louis University and undergraduate from Indiana University Bloomington.

View all posts by Andie Schieler

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