The November 15 deadline is fast approaching for sponsors of group health plans to provide their Medicare-eligible beneficiaries with a notice advising them whether or not the employer coverage for prescription drugs is actuarially equivalent (creditable coverage) to the Medicare Part D drug coverage. Medicare-eligible individuals need to know this because the Medicare Part D prescription drug imposes a premium penalty for each month that a Medicare-eligible individual delays enrollment in Part D, other than when enrolled in an actuarially equivalent prescription drug plan.

 

Because employers may not know if a dependent or spouse is on Medicare, they should provide the Notice to all health plan participants. The last notice was sent prior to November 15, 2007. The next one is due by November 15, 2008.

• The updated guidance is available at http://www.cms.hhs.gov/CreditableCoverage/
  
  
• The model notices are available on the CMS website at
  http://www.cms.hhs.gov/CreditableCoverage/09_CCafterJune15.asp#TopOfPage

David Martin Agency has again checked with the area’s major insurers and outlined their responses below. Please note that while we have made every attempt to ensure this information is correct, we cannot guarantee the accuracy of the response as insurers have been known to change their responses.

• Blue Cross Blue Shield of Minnesota - has indicated they will send the Notices for all fully-insured groups. For Creditable plans, members age 64+ and who are disabled will receive Notices. For Non-Creditable plans, members age 55+ and who are disabled will receive Notices. The Notices are scheduled to be sent at the end of October. BCBSMN will not send Notices for self-funded groups.
  
  
• HealthPartners - has indicated they will provide this service for all fully-insured groups. Self-insured group members will receive the Notice only if you have requested Notice service from HealthPartners.
  
  
• Medica - has indicated they will provide this Notice to enrollees for fully-insured plans on the group's behalf. Medica will also provide Notices on behalf of self-insured employers who have purchased this service from Medica and have chosen the annual mailing option.
  
  
• Preferred One - has indicated they will provide the Notice for both fully-insured and selfinsured groups.

If your health plan carrier is not sending the Notice to your participants, determine whether your plan’s prescription drug coverage is creditable or non-creditable and send the appropriate Notice to all participants by November 15, 2008. For assistance in determining the creditable status of your health plan’s drug coverage, please contact your Account Executive at David Martin Agency, Inc. or your health plan carrier.

 

 

Group health plan sponsors that provide prescription drug coverage to Medicare Part D eligibles must disclose to CMS whether that coverage is creditable within 60 days after the start of the health plan year. Employers must complete the online Creditable Coverage Disclosure Form which can be found at https://www.cms.hhs.gov/CreditableCoverage/45_CCDisclosureForm.asp

 

 

The CMS guidance, model personalized disclosure Notice, and model generic notices for use after June 15, 2008 are posted on the CMS website: