Employers sponsoring group health plans that include prescription drug coverage are required to provide a Notice of Creditable Coverage to Medicare eligible individuals, giving them information necessary to help them understand their employer-based prescription drug coverage as they evaluate their options under the Medicare Part D prescription drug program. As part of federal health care reform, the beginning of the annual enrollment period for Medicare Part D coverage was moved up, effective in 2011, from November 15 to October 15. Accordingly, the deadline for providing the annual Notice of Creditable Coverage is now October 15, 2011. A revised sample notice reflecting the new enrollment period is available on the Centers for Medicare & Medicaid Services (CMS) website.
Employers must continue to inform CMS about their prescription drug coverage, generally within 60 days of the beginning of the plan year and at various other times, such as after a change in creditable coverage status. The disclosure to CMS must be submitted via the CMS website.
For the most part, we would expect insurers and third-party administrators to assist employers in meeting these obligations.