2022 Medicare Part D Notice of Creditable Coverage
August 9, 2022
When Congress passed the Medicare Prescription Drug, Improvement, and Modernization Act in 2003, implementing Part D drug coverage under Medicare, it required all employers that offered prescription drug benefits to provide an annual notice to all Medicare-eligible plan participants and qualified beneficiaries before October 15 of each year. This included:
Many employers send the notice to all their employees rather than trying to determine which actives, retirees, dependents, and COBRA participants are Medicare-eligible.
Employers should be preparing to send the Medicare Part D Notice of Creditable Coverage.
The notice requirement applies to all employers who offer prescription drug coverage, regardless of size, whether insured or self-funded. It also applies whether the prescription drug coverage is standalone or integrated into another plan.
The notices themselves may be sent separately or included as part of open enrollment or other benefit-related materials. They can also be sent electronically; however, the electronic method has strict rules:
Defining CreditableFor the purposes of this requirement, “creditable” means that the coverage is expected to pay as much as the standard Medicare prescription drug coverage.
Among the 2022 parameters for what is considered “standard” under Medicare D are:
Determination of Creditable CoverageThe prescription drug plan is deemed to be creditable if it:
The link below provides a calculator methodology for determining creditable coverage: https://www.cms.gov/Medicare/Prescription-Drug-Coverage/CreditableCoverage/Downloads/CCSimplified091809.pdf
Providing The Notice
There are model notices available for both ‘Creditable” and “Non-Creditable” plan designs. See below: Important Notice to those Covered under Sponsor Plans (cms.gov)Creditable Important Notice to those Covered under Sponsor Plans (cms.gov) Non-Creditable
While there are no formal penalties attached to non-conformance of the requirement, the Medicare-eligible individual may incur a late enrollment penalty if notification as to non-creditable coverage exists and that individual then attempts to enroll in Medicare Part D plan.
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