Medicare Part D Notification

What employers need to know

Medicare Part D Notice

Under the Medicare Modernization Act (MMA) employers which offer prescription drug coverage are required to notify Medicare Part D eligible individuals who are covered by, or who apply for, prescription drug coverage under the group health plan of whether or not their coverage is creditable, meaning that the coverage is expected to pay on average as much as the Medicare prescription drug coverage. This notification must be made by October 14, 2016.

Who may be eligible?
Medicare Part D eligible individuals may include active employees, disabled employees, COBRA participants and retirees, as well as their covered spouses and dependents.  To simplify administration, group health plan sponsors provide the Disclosure Notice to all plan participants. This notification is intended to help Medicare eligible individuals determine whether to enroll in a Medicare Part D prescription drug plan.

When is notification required?
Notification is required at least once a year and at the following times:

  • Prior to an individual's initial enrollment period for Medicare Part D;
  • Prior to the effective date of coverage for any Medicare-eligible individual that joins your plan;
  • Whenever prescription drug coverage ends or changes so that it is no longer creditable or becomes creditable;
  • Prior to the Medicare Part D Annual Coordinated Election Period beginning on Oct. 15 – Dec. 7 of each year; or
  • Upon the request of a beneficiary.

Where can I download sample notifications?
Creditable Coverage Model Notice Letters can be downloaded by clicking the following links:

Model Creditable Coverage Disclosure Notice

Model Non-Creditable Coverage Disclosure Notice

Employers should carefully review and customize these notices to ensure they accurately reflect their plan provisions.

Additionally, plan sponsors are required to complete an online disclosure form to the Centers for Medicare and Medicaid Services (CMS).  The disclosure should be completed at the following times:

  • No later than 60 days from the beginning of a plan year (contract year, renewal year);
  • Within 30 days after termination of a prescription drug plan; or
  • Within 30 days after any change in creditable coverage status. 

The online disclosure form can be completed at: Creditable Coverage Disclosure Form.  This is the sole method for complying with the CMS disclosure requirement.

The MMA imposes a late enrollment penalty on individuals who do not maintain creditable coverage for a period of 63 days or longer following their initial enrollment period for the Medicare prescription drug benefit.

If you have questions or for more information, call HR One's Human Resource Helpline at 1.800.457.8829.