Medicare Part D Creditable Coverage Notices: New Deadline and Revised Model Notice
Sponsors of group health plans offering prescription drug coverage must notify Medicare-eligible individuals whether their prescription drug coverage is “creditable coverage” (i.e., whether their coverage is expected to pay on average as much as the standard Medicare prescription drug coverage).
This notice must be provided prior to the first day of the Medicare Part D annual election period. Historically, the annual election period has taken place from November 15 through December 31. However, starting this year, the annual election period will now take place from October 15 through December 7. As a result, group health plan sponsors will need to distribute creditable coverage notices on or before Friday, October 14, 2011.
The Centers for Medicare and Medicaid Services (CMS) has issued an updated model notice that can be used to satisfy the creditable coverage notice requirement.
Action Required by Plan Sponsors
- Plan sponsors distributing model creditable coverage notices should use the updated CMS model notice (for use on or after April 1, 2011)
- Plan sponsors distributing customized creditable coverage notices should update their notices to reflect the new annual election period for Medicare Part D
- Plan sponsors should review and update their distribution procedures for creditable coverage notices to ensure compliance with the new October 14 deadline
Legal News Alert is part of our ongoing commitment to providing up-to-the-minute information about pressing concerns or industry issues affecting our clients and colleagues. If you have any questions about this alert or would like to discuss the topic further, please contact your Foley attorney or the following individuals:
Erik D. Vogt
Chicago, Illinois
312.832.4903
[email protected]
美国国税局法规通常规定，为避免美国联邦税务处罚，纳税人仅可依据符合法规特定要求的正式书面意见。本通讯未满足该等要求。 凡本通讯所载涉及美国联邦税务事项的书面信息，均非为避免美国联邦税务处罚之目的而撰写或提供，纳税人亦不得以此为依据规避相关处罚；且该等信息并非为支持通讯中所述任何交易或事项的推广营销而撰写。