|
|
View/Print
Tools
 |
Alerts
Group Insurance Management Services, Inc. posts these industry alerts
to provide
time sensitive or general information notifications for our
clients and visitors to our site.
We do not
offer legal advice or purport to treat all the issues surrounding any
one topic. If you have any questions regarding these alerts
or any matter posted on our website, please contact
us.
Medicare Part D Annual Alert
Reminder:
Creditable Coverage Notices Must Be
Provided before November 15 annually
 Plan sponsors must notify Medicare
Part D-eligible individuals who
receive prescription drug coverage under their plans whether their
coverage qualifies as creditable drug coverage prior to the start of
the annual Medicare Part D enrollment period for the upcoming calendar
year. These
notices must be provided before November 15 annually.
Notices
of Creditable (and Noncreditable) Coverage
Sponsors of plans providing prescription drug coverage to employees and
their dependents must notify Medicare Part D-eligible individuals
whether their coverage qualifies as “creditable”
–
i.e., is actuarially equivalent to Medicare Part D coverage. In cases
where the coverage is not creditable, notices must be provided
indicating its noncreditable status. The notice must be provided to all
Part D-eligible individuals who have prescription drug coverage
–
including active employees, disabled employees, employees on COBRA and
retirees, as well as Medicare beneficiaries who are covered as spouses
or dependents (including those spouses or dependents who may be
disabled or on COBRA) under active employee or retiree coverage.
Notices of creditable or noncreditable coverage must be provided prior
to the start of the annual Part D enrollment period for the following
calendar year. The annual
Part D enrollment period for 2008 will begin
on November 15, 2007 and end on December 31, 2007. Unless
an individual
received a notice of creditable or noncreditable coverage on or after
November 15, 2006, a new notice will have to be provided no later than
November 14, 2007.
More detailed information about the notice requirements is contained in
the Resources
section of
our website. Updated model notices of creditable and noncreditable
coverage may be found on the Centers
for Medicare and Medicaid Services website.
MEDICARE
PART D Prescription Drug Plan Creditable Coverage Disclosure
* Overview
* Disclosure
to CMS Form
* Guidance
& Model Notices for use after February 15, 2007
The Centers for Medicare and Medicaid Services (CMS) has finalized
guidance regarding disclosure notices to Medicare Part D eligible
individuals and has released model notices effective May 15, 2006.
Here are some of the highlights.
1. The creditable and non-creditable coverage notices (commonly
referred to as "generic notices") have been revised so that they're
easier to understand.
2. A new personalized disclosure notice, which can be provided in lieu
of generic notices, was released. The personalized notice
must
contain the beneficiary's name, Social Security number or health
insurance claim number, entity name and contact information, statement
that the plan is creditable or non-creditable, and the date ranges of
creditable coverage.
Heads up: In order to determine whether a Part D eligible individual
must pay a late enrollment penalty (also called a "higher premium
charge"), Part D plans are required to review either a personalized
disclosure notice or a generic notice (the latter must include proof
that the individual was enrolled during the applicable time period and
elected coverage).
3. The late enrollment penalty for Part D eligible individuals who go
without creditable coverage for 63 days or longer increases by at least
1% "of the national benchmark premium (which is set by CMS and
published each year)" for each month without creditable coverage.
4. In order to qualify for the simplified determination of creditable
coverage status, an integrated plan is defined as any plan of benefits
offered to Medicare eligible individuals where the prescription drug
benefit is combined with other coverage offered by the entity (medical,
dental, etc.) and the plan has certain plan provisions evidencing
combined plan year deductibles, annual benefit maximums, and lifetime
benefit maximums.
5. The disclosure notice requirement applies to Medicare beneficiaries
who are "active employees, disabled, on COBRA and those individuals who
are retired," as well as Medicare beneficiaries who are covered as
spouses or dependents (including spouses or dependents who are disabled
or on COBRA) under active employee coverage and retiree coverage.
|
|
