It’s that time again –  time to send a Medicare Part D notice of creditable coverage to your eligible employees letting them know if the prescription drug coverage you offer them is creditable. A group health plan’s prescription drug coverage is considered creditable if it is at least as generous as Medicare Part D prescription drug coverage.

Who Needs to Notify Their Employees?

All employers, regardless of size, who sponsor group health plans with prescription drug coverage must provide the annual disclosure notice to Medicare-eligible individuals before Oct. 15, 2017-the start date of the annual enrollment period for Medicare Part D.

Which Employees Do I Need to Notify?

• You are required to give the creditable-coverage notice to all Part D-eligible individuals who are covered under, or apply for, an employer’s prescription drug benefits plan. This requirement applies to Medicare beneficiaries who are active employees and those who are retired, as well as Medicare beneficiaries who are covered as spouses under active or retiree coverage.
• To alleviate the responsibility of determining who is “Medicare-eligible” participant, HR Knowledge recommends that you provide this notice to ALL employees enrolled in your employer-sponsored medical plans. 

Steps for Employers

1. Determine if your group medical plan(s) is creditable or non-creditable.
2. Use the appropriate Creditable Coverage Blanket Notice Template we have provided, filling in the information specific to your organization.
3. Disclosure #1: Communicate your plan(s) status by sending a blanket mailing to all participants and their dependents (including COBRA participants). This mailing must be conducted prior to the October 15, 2017, deadline.
4. Disclosure #2: Complete and submit the CMS disclosure registration online.

Disclosure Requirement #1

HR Knowledge has prepared a Creditable Coverage Blanket Notice Template and a Non-Creditable Coverage Blanket Notice Template that is available for your use. It contains all the required elements – but requires you to fill in your specific information where indicated in red print (employer name, plan name, contact information, etc.). The CMS website also has the template available in Spanish.

If you are aware that a covered spouse or dependent child resides at a different address from the employee, you must mail a separate notice to that address.

Template Notices

• Creditable Coverage Blanket Notice Template
• Non-Creditable Coverage Blanket Notice Template

Note: If you are one of our full-service clients, we can customize your onboarding process to include this notice after October 15, 2017, and post this notice to your employee portal on ADP. Please contact us to learn more.

Creditable or Non-Creditable Coverage

Medical Carrier	Number of Full Time Equivalents (FTE’s)*	Creditable	Non-Creditable
Blue Cross Blue Shield of MA	1-50	Contact HR Knowledge**
	51 +	Contact HR Knowledge
Harvard Pilgrim Health Care	1-50	Yes
	51 +	Contact HR Knowledge
Tufts Health Plan	All	Contact HR Knowledge
United Health Care	All	Contact HR Knowledge
Other	All	Contact HR Knowledge

**If you have 1-50 FTE’s and DO NOT offer a Saver plan, your plan is creditable. If you have 1-50 FTE’s and DO offer a Saver plan, your plan is non-creditable but may be considered creditable if an HRA is offered.* An FTE is the hours worked by one employee on a full-time basis. The concept is used to convert the hours worked by several part-time employees into the hours worked by full-time employees.

If you are unsure as to whether or not your group health plan meets Medicare Creditable Coverage guidelines please contact us for assistance.

To communicate your plan(s) status, we recommend that you conduct a blanket mailing to all participants and their dependents (including COBRA participants), because you may not be aware of a dependent’s Medicare eligibility (such as a spouse over 65 or disabled dependents). This mailing must be conducted prior to the October 15, 2017, deadline.

Disclosure Requirement #2

As a health plan sponsor, your organization must notify CMS of your plan’s creditable coverage status on an annual basis. You are required to provide the disclosure notice to CMS by completing the disclosure form on the CMS webpage. The Disclosure to CMS Form is available on the left hand side menu, under Creditable Coverage. Instructions to completing the form are in the same location, titled, Disclosure to CMS Guidance and Instructions.Completing and submitting the form online is the only allowable way to provide CMS with the notice. You must complete the disclosure annually, no later than 60 days from the beginning of a plan year (contract year, renewal year), within 30 days after termination of a prescription drug plan, or within 30 days after any change in creditable coverage status.

Each employer must report to CMS directly, HR Knowledge is unable to do this on your behalf.

Additional Resources

View the Medicare Part D Notices HR Knowledge Compliance Bulletin.

The CMS Creditable Coverage website provides the complete text of the guidance and sample disclosure notices. Plan sponsors should carefully review and customize these notices to ensure they accurately reflect their plan provisions.

If you are unsure as to whether or not your group health plan meets Medicare Creditable Coverage guidelines, or need assistance in completing these requirements please contact us for assistance.