Health plans that provide prescription drug coverage to Medicare Part D eligible individuals must notify these individuals whether the drug coverage they have is creditable or non-creditable. The Centers for Medicare and Medicaid Services has made two changes to this requirement:
- New model notices are now to be used.
- Notices now must be sent by October 15 each year. The deadline was previously November 15.
The model notices, in English and Spanish, can be found at: https://www.cms.gov/CreditableCoverage/Model%20Notice%20Letters.asp#TopOfPage
Since plan sponsors often do not know if a covered dependent is eligible for Medicare, particularly due to disability or end-stage renal disease, it is a safe course of action to send the notice to all participants. Plan sponsors can include this notice in open enrollment packets sent to all participants, if the October 15 deadline works with open enrollment schedules, otherwise, a separate mailing will be necessary. A short cover note explaining why the notice is being sent can prevent calls from confused recipients.