The October 14 deadline for furnishing the annual notice of creditable (or noncreditable) prescription drug coverage, required in connection with Medicare Part D, is fast approaching. Generally, this notice informs medicare-eligible health care plan participants, who are afforded prescription drug coverage under the plan, whether such coverage is creditable coverage or not. The coverage is “creditable” if it is expected to pay on average as much as the standard Medicare prescription drug coverage. Notice would not be required from a plan providing certain “qualified” prescription drug coverage.
The Centers for Medicare and Medicaid Services (the “CMS”) had made available model notices, last updated April 1, 2011. The model notice for creditable coverage is here. The model notice for noncreditable coverage is here.
As a separate disclosure requirement, the employer maintaining a health care plan providing prescription drug coverage is required to complete an online disclosure to CMS, to report the creditable coverage status of this coverage. The disclosure must be completed annually, by no later than 60 days after the beginning of the plan year, or within 30 days after any change in creditable coverage status. The CMS website containing information pertaining to the notice and disclosure is here.