Employers: Medicare Part D Compliance – Action Needed
September 8, 2016
Employers with group health plans that provide prescription drug coverage to individuals who are eligible for Medicare Part D must comply with certain disclosure requirements. Employers must disclose to individuals who are eligible for Medicare Part D and to the Centers for Medicare and Medicaid Services (CMS) whether their prescription drug coverage is at least as good as the Medicare Part D coverage (in other words, whether their prescription drug coverage is “creditable”). These disclosures must be provided on an annual basis and at certain other designated times.
Which Employers Are Impacted? Employers With A Medical Plan That Includes Prescription Coverage.
What do employers need to do? There are two disclosure requirements:
1. Employers must provide creditable or non-creditable coverage disclosure notices to individuals (employees and dependents) eligible for Medicare Part D each year before Oct. 15 (the start date of the annual enrollment period for Medicare Part D). The notice must be given at certain other times as well; see attached “Medicare Part D Disclosure to Members.”
**Watkins provides a customized Medicare D creditability notice in your Employee Benefits Enrollment Guide; feel free to use the notice that we have customized for you.
2. Disclose to CMS, on an annual basis and at certain other times, whether the coverage they provide is creditable or non-creditable. The disclosure to CMS is due within 60 days after the start of each plan year; see attached “Medicare Part D Disclosure to CMS.” Employers must report this using CMS’ online form: https://www.cms.gov/Medicare/EmployerDisclosure.
Please contact our experts at Watkins Insurance Group if you have any questions. (512) 452-8877