As  Fall approaches, we should all be starting to think about the next plan year. When it comes to prescriptions drugs, there are some important deadlines just around the corner. Medicare Part D notices must be provided to employees by October 15, 2020. We’re here to answer your Medicare Part D questions!

What is a Medicare Part D notice and what does it do?

The Medicare Prescription Drug, Improvement, and Modernization Act of 2003 added a voluntary prescription drug benefit to the Medicare program (Medicare Part D). The Act includes an annual notice requirement for employers that offer a prescription drug coverage program to individuals who are eligible for Part D coverage. The notice is a declaration of whether the prescription drug coverage is “creditable.”

For this purpose, “creditable” coverage is prescription drug coverage through an insurer (or employer) that, on average, pays out at least as much as the standard coverage available through a Medicare prescription drug plan. Though there are a few exceptions, most employer-sponsored group health plans must comply with the Medicare Part D disclosure requirement.

The enrollment period for Medicare Part D occurs yearly from October 15th  to December 7th. So, the deadline for disclosing information to eligible individuals and plans sponsors for this year is October 15, 2020.

Click here to read our previous post on Medicare Part D disclosure and eligibility.

What other important upcoming deadlines should I know about?

The Act also requires an employer to send a disclosure notice to the Centers for Medicare and Medicaid Services (CMS) about the prescription drug plan’s ‘creditable’ coverage status. The Notices to CMS are generally sent electronically through the CMS website at the following times:

• Within 60 days following the start date for the plan year;
• Within 30 days following the termination of the prescription drug plan;
• Within 30 days following any change in the creditable coverage status of a prescription drug plan.

How can Medicare Part D disclosures be delivered to employees?

Plan sponsors have options when it comes to providing notices for creditable coverage disclosure. Disclosure notices can be provided separately or with other plan participant materials. Disclosure notices can also be sent electronically, if done in in compliance with U.S. Department of Labor regulations.

Generally speaking, the electronic distribution regulations allow a plan sponsor to provide certain notices electronically  to plan participants that either have access to the sponsor’s electronic information system as part of their regular, day-to-day work duties or have previously provided authorization to receive disclosure notifications electronically.

What’s important is that the plan sponsor utilizes appropriate and reasonable measures to properly transmit the information and ensure that it is received. Regardless of delivery method, a paper version of the documents must be available upon participant’s request. Additionally, if a plan sponsor opts to use electronic delivery, the sponsor must inform the plan participant that they are responsible for providing a copy of the electronic document to their eligible dependents covered under the plan.

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