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Medicare Part D Notification

All group health plans that provide prescription drug coverage to Medicare Part D eligible individuals are required to report to the Centers for Medicare and Medicaid Services (CMS) annually if the coverage is credible or not. There are a few exceptions - plans that contract with Medicare directly for Part D, or with a Part D plan to provide qualified coverage are exempt.

If an entity does not offer prescription drug benefits to any Medicare Part D eligible individual on the beginning date of their plan year (renewal year, contract year, etc.), the entity is not required to complete the Disclosure to CMS Form for that plan year. The filing is the responsibility of each employer who sponsors a Group Health Plan. The report form is extremely simple, is available on line, and takes only minutes to complete! Please contact us if you have any questions while filing out the report. You can find the report form at https://www.cms.hhs.gov/CreditableCoverage/45_CCDisclosureForm.asp

The deadline for filing the initial disclosure via the report form with CMS is within 60 days of the beginning of the plan year that the disclosure refers to. This will need to be done every year at this time. For example if you renew 10/1/10, you must complete the filing by 12/1/10.

A separate disclosure form should be completed for each separate plan type maintained by an employer entity if multiple health plans are offered (e.g. regular employer plan, dual option medical plans, Medigap, etc). If an entity has subsidiaries, one form can be used for all if the plan year is the same.

A CMS list of who must provide disclosure can be found at: http://www.cms.hhs.gov/CreditableCoverage/Downloads/ENTITIESREQUIREDTOPROVIDEDISCLOSURE.pdf

A CMS webpage with the instructions on completing the form and giving an overview of the regulatory requirements and policy guidance can be found at: http://www.cms.hhs.gov/CreditableCoverage/Downloads/Disclosure2CMSGdnc.pdf

Additionally, you are required to let your employee's know this information each year by November 15th. You can find sample letters by following the link above.

Feel free to contact your Account Representative at JLR & Associates LLC if you have any questions at (425) 391-4141.