New October 15 Deadline for Medicare Part D Creditable / Non-Creditable Coverage Notices

Group health plans that offer prescription drug coverage are required to issue a notice of creditable or non-creditable coverage to Medicare-eligible participants and beneficiaries each year prior to the annual Medicare Part D open enrollment period.  In the past, the Medicare Part D open enrollment period ran from November 15 through December 31, so the notice had to be provided by November 15.  The Patient Protection and Affordable Care Act moved the Medicare Part D open enrollment period earlier, beginning in 2011, to October 15 through December 7.  Therefore, this year's notice of creditable or non-creditable coverage must be provided by October 15, 2011.

A plan's notice of creditable or non-creditable coverage describes whether prescription drug coverage under the plan is "creditable" — i.e., expected to pay out at least as much as standard Medicare prescription drug coverage, on average for all participants.  This information is designed to help Medicare-eligible individuals avoid late enrollment penalties, which can apply when an individual who does not have creditable coverage fails to enroll in Medicare Part D when first eligible.

Plan sponsors will need to update their notices of creditable or non-creditable coverage to reflect the new dates for the Medicare Part D open enrollment period.  The Centers for Medicare and Medicaid Services have updated their model notices of creditable and non-creditable coverage to reflect the new dates.  No other substantive changes were made to the model notices.  The updated notices are available here.