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Deadline Reminder

Medicare-eligible policyholders must be notified of whether their prescription drug coverage is creditable coverage — meaning the coverage is expected to pay on average as much as the standard Medicare prescription drug coverage — before October 15th.

The Medicare Prescription Drug Improvement and Modernization Act of 2003 (MMA) requires all employer-sponsored health plans with prescription drug coverage to provide a Part D notice to each covered person who is, or who is about to become, eligible for Medicare.  A Disclosure Notice advises as to whether or not the plan’s prescription drug coverage is at least as good as the prescription drug coverage under the Part D program.

The purpose of the Disclosure Notice is to enable a plan participant to make an informed decision about enrolling in Part D prior to initial eligibility for Medicare, and enables Medicare eligible individuals to decide to replace their current coverage with Part D.  

An updated Disclosure Notice must be provided prior to the Part D annual enrollment period of October 15th , annually, may be provided with other plan information materials (such as enrollment materials) and at other prescribed times (including upon request, and prior to a an individual’s initial enrollment period for Part D, or whenever prescription drug coverage ends) but need not be sent as a separate mailing.  

Note:  The October 15 “participant” notice requirement is different from the annual plan sponsor obligation to tell CMS whether the plan is providing “creditable coverage” or not.  Information about electronic notification to the government (disclosure to CMS) can be found by clicking on the following LINK