23 September 2016
23 September 2016,
 0

Medicare Part D Disclosure Model Notices & CMS Disclosure Instructions – Required notice 10/15/16

The Medicare Modernization Act (MMA) requires employers whose policies include prescription drug coverage to provide a written disclosure notice to all Medicare eligible policyholders of whether such coverage is creditable. Creditable coverage means that the coverage is expected to pay, on average, as much as the standard Medicare prescription drug coverage.

This disclosure must be provided prior to October 15th, 2016 (and at various times as stated in the regulations) to:

  • – Medicare eligible active working individuals and their dependents (including a Medicare eligible individual when he or she joins the plan);
  • – Medicare eligible COBRA individuals and their dependents;
  • – Medicare eligible disabled individuals covered under an employer’s prescription drug plan; and
  • – Any retirees and their dependents.

Please see the attached Model notices available for distribution. 

Additional Disclosure Requirements 
Under the law, employers must also complete an online disclosure to CMS to report the creditable coverage status of their prescription drug plan at certain intervals.

The disclosure submission process is composed of the following steps to complete the online Creditable Coverage Disclosure Form available via the following link:

https://www.cms.gov/Medicare/Prescription-Drug-Coverage/CreditableCoverage/CCDisclosureForm.html

Disclosure to CMS Instructions:

Step 1 -Enter the Disclosure Information

Step 2 -Verify and Submit Disclosure Information, and

Step 3 -Receive Submission Confirmation

Please see the attached ‘Disclosure to CMS Instructions’ for further information on completing the online Creditable Coverage Disclosure form.

CredCovDisclosureGuidance.pdf

Disclosure-to-CMS-Instructions.pdf

ModelCreditableCoverageDisclosureNotice051711.pdf

ModelNonCreditableCoverageDisclosureNotice051711.pdf

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