Medicare Part D Blanket Notification due before November 15 of each year
As a result of the Medicare Prescription Drug, Improvement, and Modernization Act of 2003 (MMA), employers offering group health plan coverage with a prescription drug benefit are required to notify all Medicare participants before November 15 of each year whether that coverage constitutes "creditable prescription drug coverage."
Infinisource Blanket Notification Mailing
Infinisource can help employers satisfy the annual notice requirement for the annual November 15 deadline by generating a customized Creditable Coverage or Non-Creditable Coverage Notice and sending it to your entire participant population. Please see Memorandum of Agreement and Data Sheet Instructions.
Summary of Employer Requirements
Medicare Part D went into effect on January 1, 2006. Medicare participants may enroll in Part D starting November 15 of each year. Employers offering group health plan coverage with a prescription drug benefit are required by that date to notify all Medicare participants whether that coverage constitutes “creditable” prescription drug coverage. Required recipients include not only Medicare-enrolled employees, but also any retirees, COBRA beneficiaries, their spouses and dependants who are on Medicare. To be considered creditable coverage, an employer’s group health plan must answer a key question: on average, will the expected claims payout by the employer’s plan equal or exceed those paid under Part D? To answer this question, employers can use the Self Determination Test provided by Infinisource.
Notice of Creditable Coverage Requirements
Employers must notify affected participants whether their plans constitute creditable coverage before November 15 of each year. If the plan offers creditable coverage, the notice must indicate, define creditable coverage and explain why it is important. If the plan does not offer creditable coverage, the notice must include creditable coverage notice content as well as information about when to enroll in Part D.
Failure to Provide Notification of Creditable Coverage
Eligible employees have until December 31 each year to enroll in Part D. Eligible employees who enroll in Part D after that date will have to pay a late enrollment penalty in the form of higher premiums – at least 1 percent per month the employee is late. In addition, ERISA generally requires plan fiduciaries to comply with all applicable federal laws.