November 14 is Important Date for Employers with Prescription Drug Plans

Go to your planning calendar and if November 14, 2006, does not have any reminders or notations, it should. That is the annual Medicare Part D disclosure deadline for employers with group health plans offering prescription drug coverage.

Medicare Part D requires employers to make an annual assessment of whether their plans offer creditable prescription drug coverage. A plan has creditable coverage if its actuarial value equals or exceeds the actuarial value of the standard Medicare Part D drug benefit. Infinisource has conducted numerous seminars and webinars on this requirement, including a short test for making the creditable coverage determination. You can reference some of our articles by visiting our News & Review archive at: www.benefitsolved.com/news/benefits_news_archive.asp#medicare.

In September, the Centers for Medicare and Medicaid Services (CMS) published revised guidance on the disclosure notices and updated its three model notices for creditable coverage, non-creditable coverage and personalized disclosure (optional). Major changes include the following:

• The break-in-coverage rule was clarified by making it 63 “continuous” days. After 63 days, late enrollment would be subject to a late penalty.
• A 60-day Special Enrollment Period is available to those who lose employer-sponsored drug coverage through no fault of their own.
• CMS confirmed that the Personalized Notice – a notice that first came on the scene last May – is merely recommended, not required. Personalized notices do not require a Social Security Number, as indicated in the previous model notice. Instead, an employee’s date of birth or “unique member identification number” will suffice.

Technically, these new model notices are merely draft documents. Employers may use either these notices or the May 2006 versions. After a 30-day public comment period, CMS will issue final notices.

Infinisource recommends that employers mail Medicare Part D notices via first class mail to all plan participants due to the difficulty of determining which participants are currently Medicare Part D eligible. Payroll stuffers generally will not suffice if a spouse or dependent is entitled to the notice. In addition, there are strict requirements for electronic transmission of the notice, and most employers will not want to expend the necessary time and effort.

Similar to 2005, Infinisource is offering Medicare Part D notice mailing to clients that either are not handling this themselves or do not have a carrier or other entity handling this for them. Our notices meet all of the content requirements, including the minor changes in the September guidance, but are organized in a simpler, more understandable format. If interested, you can simply e-mail us at medicared@infinisource.net or call us at 800-300-3838.

A copy of the recent CMS guidance is available at: www.benefitsolved.com/benefit_resources/benefit_links.asp#Medicare.

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