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Employer group health plans that include prescription drug coverage must provide a notice each year to all Medicare-eligible employees and dependents before the annual October 15th Medicare Part D enrollment period. The notice describes whether the employer’s prescription drug coverage is at least as good as Medicare’s prescription drug coverage (i.e., creditable coverage). If an employer’s coverage is not considered creditable, Medicare eligible individuals can incur a late enrollment penalty for failing to timely enroll in Medicare Part D, so the notice can help them make an informed enrollment decision.
This alert provides a summary of which employers are subject to the requirement, model notices available from the Centers for Medicaid & Medicare Services (CMS) and guidelines for delivery, as well as reporting to CMS.