September 19, 2017
Employers must notify individuals who are eligible to participate in their medical plan whether the plan’s prescription drug coverage is “creditable” or “non-creditable” as compared to Medicare Part D coverage.
The notice must be provided to Medicare Part D-eligible individuals on an annual basis prior to Oct. 15, which is the first day of the Medicare enrollment period. Thus, the notice must be provided no later than Oct. 14 each year. Note that for 2017, since Oct. 14 falls on a Saturday, many employers should ensure that delivery of this notice has occurred by Friday, Oct. 13, 2017. It is recommended that the notice be sent to all employees who are eligible to participate in the employer’s medical plan.
This important notice assists eligible individuals in deciding whether to enroll in Medicare Part D prescription drug coverage. Because an individual can be eligible for Medicare due to age or disability, or an employee's spouse or dependent can be eligible for Medicare, it might be difficult for an employer to identify plan participants who are Medicare-eligible (and therefore must receive the Creditable/Non-Creditable Coverage notice). To avoid this difficulty (and for purposes of administrative simplicity), the recommended approach is for the notice to be distributed to all employees who are eligible to participate in the plan. The preferred method of delivery is first-class mail, although it is possible to distribute the notice electronically as long as certain conditions are met.
For more information, please contact your advisor for a copy of “Medicare Part D Guidance for Employer Deadlines.” You can also read more information about this requirement on the HR & Benefits Compliance Solutions website.