The Centers for Medicare and Medicaid Services (CMS) has issued guidance regarding disclosure of creditable coverage to Medicare Part D eligible individuals. This information is available on the CMS website at www.cms.hhs.gov/creditablecoverage.
The guidance reiterates that:
- An employer must disclose the status of their prescription drug coverage to CMS on an annual basis and upon any change in the status. The only way to disclose this information to CMS is via the Web at www.cms.hhs.gov/creditablecoverage.
- A disclosure notice must be provided to all Part D eligible individuals who are covered under or apply for an employer's prescription drug coverage.
- At a minimum, disclosure to an employer's employees and their dependents on the employer's group plan must be made at the following times:
- Prior to the Medicare Part D annual coordinated election period – October 15 through December 7 of each year
- Prior to an individual’s initial enrollment period for Medicare Part D
- Prior to the effective date of coverage for any Medicare eligible individual who comes on to the employer's group coverage
- Whenever an employer no longer offers prescription drug coverage or the status of the employer's prescription drug coverage changes
- Upon a Medicare beneficiary’s request
Please refer your employer groups directly to CMS’ guidance using the link provided above to assure they are in compliance. The guidance provides an outline of what the employer must communicate and what is recommended the employer communicate as well as sample notices.
To help employers communicate this information to their group members, sample notices are provided below. These notices contain all of the required information and most of the recommended information.
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