A little-noticed provision in PPACA has moved up the Medicare Part D annual enrollment period from November 15 through December 31 to October 15 through December 7. This change is effective beginning with 2012 Medicare Part D enrollment, which will take place this fall.

Since group health plans must provide notices to Part D-eligible individuals as to whether their prescription drug coverage is creditable or non-creditable, plan sponsors will want to ensure that the Medicare Part D Notices of Creditable or Non-Creditable Coverage they provide this year accurately describe the shift to an earlier enrollment period. CMS has updated its Model Notices to reflect the new enrollment period of October 15 through December 7.

These Medicare Part D Notices must be provided prior to the beginning of the Medicare Part D enrollment period each year, which means that starting this year, they will need to be provided earlier – before October 15th, instead of before November 15th.  Plan sponsors who generally provide Medicare Part D Notices in their annual enrollment materials will want to keep this earlier deadline in mind; if other annual enrollment materials are not ready to be distributed by October 15, plan sponsors will need to provide the Medicare Notices separately before that date.