Medicare Part D Notices are Due by October 15, 2019

Employer groups that offer a group health plan must create and distribute the Notice of Creditable/Non-Creditable Prescription Drug Coverage on, or before, October 15, 2019; which is also the start date of the Medicare Annual Election Period. Because it may be difficult to identify all Medicare Part D eligible participants in the group health plan, it is suggested that the disclosure be provided to all plan participants.

The creditable or non-creditable coverage notice alerts the individual if their employer group plan’s prescription drug coverage is at least as good as the Medicare Part D coverage. Medicare beneficiaries who are not covered by creditable prescription drug coverage and who choose not to enroll in a Medicare Part D plan before the end of their Medicare initial enrollment period will be subject to a penalty if they enroll in Medicare Part D at a later date.

CMS has provided model creditable coverage notices for plan sponsors to use. Plan sponsors are not required to use the model notices; they can choose to draft their own notices as long as it contains all of the legally required elements. The CMS Model Creditable Coverage Disclosure Notice should be used when prescription drug coverage is creditable. When prescription drug coverage is not creditable, the Model Non-Creditable Coverage Disclosure Notice should be used.

The CMS Model Creditable/Non-Creditable Disclosure Notices in English and Spanish in addition to carrier Medicare Part D creditable coverage plan lists are available in Resources on the RBG website