The Medicare Part D regulations issued by the Centers for Medicare and Medicaid Services (“CMS”) require group health plans providing prescription drug coverage to Part D-eligible individuals to disclose to participants whether the coverage is “creditable” — that is, at least as good as Medicare Part D coverage. Plans must send these notices to participants each fall, prior to the beginning of the initial enrollment period for Medicare Part D coverage.
CMS has once again revised the model notices of creditable coverage for use on or after June 15, 2008. No major changes have been made to the content of the notices. The format has been reorganized, however, and subheadings have been added to make the notices easier to read. In addition, some portions of the notices have been expanded to provide more detail about Medicare’s special enrollment period.
Plan sponsors do not need to redistribute this notice immediately; however, sponsors who use the model disclosure notices will likely want to begin using the updated versions. Those using customized versions of the notices may wish to review the new model notices to see if any of the changes should be incorporated. The new model creditable and non-creditable notices and personalized notices are posted on the CMS website.