Medicare Part D Notification Requirements
Medicare Part D is a voluntary prescription drug benefit. There are two notification requirements tied to this benefit: One to Centers for Medicaid and Medicare Services (CMS) and one to individuals. Individuals are required to pay a premium penalty for each month they are not enrolled in Medicare Part D, but they will not be penalized if they are enrolled in a creditable prescription drug plan. For this reason, these Medicare Part D notice requirements are vital.
To whom does this apply?
This applies to group health plans that offer prescription drug benefits to Medicare Part D–eligible individuals (with eligibility based on attaining age 65 or being disabled prior to age 65).
- Plans offered by employers.
- Union/Taft-Hartley plans.
- Church and governmental plans.
- Plans that provide coverage of prescription drugs to veterans.
- Plans that provide military coverage (including TRICARE).
- Coverage provided by tribal organizations.
- Qualified retiree prescription drug plans.
- Plans that offer coverage under a Medicare supplemental policy.
|Notice to CMS||Notice to Individuals|
|When must the certification be sent?||
The annual CMS notice must be given online, at the CMS website, within:
Plans must also notify Medicare Part D–eligible individuals* of the status of their prescription drug coverage at a minimum as follows:
|What information must the certification contain?||
Plan sponsors should have the following information available when completing the online certification to CMS:
|For the individual notice, sample notices and guidance can be found on the CMS website|
*Technically, this notice must be provided only to covered individuals entitled to Medicare Part D; though most employers provide it to all individuals covered by the plan. This is because it is impractical (and often impossible) for employers to know which individuals covered by their plan are entitled to Medicare Part D. CMS has indicated that a single notice may be provided to one household, unless it is known that any spouse or dependent resides at a different address than the employee.
What will Meritain Health do to assist with this requirement?
If Scrip World is your PBM vendor, you may request that Scrip World perform the simplified test as described by the Centers for Medicare & Medicaid Services. Once the test is complete, Scrip World will notify you if your coverage is creditable or non-creditable. Please contact your Meritain Health client relationship manager to request this test. If a plan was creditable last year and the plan did not change its plan design since its last renewal, it can rely on the analysis performed last year to make this year's decision. We do not perform this test for groups who do not use Scrip World as their PBM vendor.
Employers should confirm they have marked their calendars accordingly, based on the above deadlines, to ensure they satisfy their Medicare Part D notification requirements.
If you have questions, please contact your Meritain Health representative or client relationship manager.
Compliance Corner is being provided as an informational tool. It is recommended that plans consult with their own experts or counsel to review all applicable federal and state legal requirements that may apply to their group health plan. By providing this publication and any attachments, Meritain Health is not exercising discretionary authority over the plan and is not assuming a plan fiduciary role, nor is Meritain Health providing legal advice.