Employers sponsoring a group health plan with prescription drug benefits are required to notify their Medicare-eligible participants as to whether the drug coverage provided under the plan is ‘creditable’ or ‘non-creditable’. Creditable means that the insured RX plan is equal to or better than the Plan D RX coverage under Medicare. NOTE THAT ALL INSURED GROUP PLANS (Keystone, Aetna, UHC, HighMark, UPMC) MEET THE ACTUARIAL REQUIREMENTS TO BE CONSIDERED CREDITABLE.
Employers should send these notices no later than October
15, 2020.
In order to assist employers in their compliance obligations,
CMS has issued participant disclosure model notices for
both creditable and non-creditable coverage, which can be
found at:
https://www.cms.gov/Medicare/Prescription-Drug-Coverage/
CreditableCoverage/Model-Notice-Letters (notices last
updated by CMS for use on or after April 1, 2011).
These model notices, when appropriately modified, will
serve as a proper notice for purposes of this requirement. You can also update the notice you sent last year since the model notice has not changed.
Please contact BMC if you have any questions.
