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 primarily applies to medical/Rx coverage, including both self-insured and fully insured plans.
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.
