Beginning this year, the annual enrollment period for Medicare Part D and Medicare Advantage will begin October 15 and end December 7. This means that plan sponsors must provide creditable (or non-creditable) coverage notices one month earlier than in prior years (October 15 rather than November 15). To reflect this change, the Centers for Medicare and Medicaid Services (CMS) revised the model Part D notices.
A common practice among employers who operate calendar year plans is to provide the required Part D notice as part of the annual open enrollment material. Beginning this year, plan sponsors may continue this practice only if the plan’s open enrollment materials are distributed before October 15; otherwise, the Part D notice will need to be furnished separately.
Updated model notices are available on the CMS website. Plan sponsors should review the new notices and revise them as necessary to reflect the terms of their plan. Part D notices must also be furnished prior to the effective date of coverage for any Medicare-eligible individual who enrolls in the plan, if employer-sponsored coverage is terminated, if the plan sponsor’s drug coverage changes from creditable to non-creditable (or vice versa), and upon request.