CMS Medicare Part D Notification deadline is November 15th
The Medicare Modernization Act (MMA) mandates that certain entities offering prescription drug coverage, including employer and union group health plan sponsors, disclose to all Medicare eligible individuals with prescription drug coverage if the current health coverage they have is “creditable.” This information is essential to an individual’s decision whether to enroll in a Medicare Part D prescription drug plan. MMA imposes a late enrollment penalty on individuals who do not maintain Creditable Coverage for a period of 63 days or longer following their initial enrollment period for the Medicare prescription drug benefits. Each year, the notification of creditable coverage must take place prior to November 15th. While the legislation requires the notice only be sent to the Medicare eligible population, WGA recommends that clients send the document to all participants in the plan, this includes COBRA participants and those in the COBRA election period. t’s the safest course of action since there is no way for an employer to definitively know who is and who is not eligible for Medicare coverage. Medicare can extend not only to those aged 65 and over, but to some individuals who are disabled.
The approved distribution methods for the required Medicare notification are similar to those for Summary Plan Descriptions. An electronic distribution of the notice is acceptable to those with access to email as a regular part of their job with the ability to open and print the document. For others in the workforce, who may not have direct access to a computer, regular mail is necessary. For assistance determining the creditability of the offered prescription drug plan, please contact your Account Executive or Account Manager at WGA.