Annual reminder: Medicare Part D (Creditable Coverage) Notices due to individuals

Employer group health plans that include prescription drug coverage must provide a Medicare Part D creditable and/or non-creditable coverage notice (“Notice”), as applicable, each year to all Medicare-eligible employees and dependents before the annual October 15th Medicare Part D enrollment period. The rule usually only applies to medical/Rx coverage, and self-insured or fully insured plan status does not matter.

This Alert summarizes how to determine creditable coverage, who should receive the Notice, and the Notice contents and delivery requirements. This Alert is relevant for any employer that offers prescription drug benefits to employees (including former employees) and their dependents.