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Friday, 06 September 2019 13:30

Compliance Alert: Medicare Part D Notice due October 15th

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The Medicare Part D Notice is just one of the many compliance responsibilities to which most employer health plans are subject. Since this notice is due in just a couple of weeks, here’s what you need to know: 

There are 2 main employer responsibilities when it comes to Medicare Part D coverage:

  • Send the creditable/non-creditable Notice to plan participants

  • Certify the creditability status of your plans on the CMS website

Let’s look at both of these requirements in more detail.

The Notice informs participants of the creditability status of their health plans compared to Medicare Part D (prescription) benefits. For coverage to be considered creditable, it must be expected to pay as much on average as Medicare Part D. Anyone eligible for Medicare needs to know the status of their employer’s prescription plan to help them determine whether they need a Part D plan or not. Failure to switch from non-creditable prescription drug coverage to Medicare Part D can result in late fees. Providing a creditable Notice will help prevent your employees from being penalized. Since the Medicare open enrollment window starts on October 15th each year, the Part D Notices need to go out to employees by then to give them plenty of time to make any necessary adjustments to their coverage.

When we audit employers on ERISA and other compliance responsibilities for the first time, they often say, “I don’t have any employees over 65, so I don’t need to send the Notices.” We quickly point out that’s not where their responsibility ends. A person under 65 can be Medicare-eligible if they are disabled, or in end-stage renal failure. While you may know the status of all your employees, you may not know the status or even age of all the dependents on your plan.

As a good practice, Fall River recommends to our clients that employers send out the Notice annually to all employees, to make sure you’re capturing anyone in the family that might be Medicare-eligible. We also recommend that the Notice be included in the new hire package.

In addition to sending the Notice, employers must also certify whether their plan is creditable or non-creditable on the CMS website within 60 days of the beginning of each plan year. This allows CMS to look up the status of a participant’s plan and helps to make the Medicare enrollment process simpler and faster.

Fall River clients will be receiving their fully-customized Medicare Notices shortly. For those who are not yet part of the Fall River family, click here to download the latest Medicare Part D creditable and non-creditable Model Notices. As always, if we can help with this requirement in any way, please contact us

Read 1506 times Last modified on Monday, 14 September 2020 10:39
Colin Powers

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