U.S. Department of Health and Human Services regulations require an annual notice to all plan participants regarding the Medicare Part D Prescription benefit “creditability” of your group health plan. This notice must be provided prior to October 15th to coincide with the annual Medicare open enrollment period which runs from October 15th to December 7th. This notification provides Medicare-eligible employees with important information they need in order to decide whether they should enroll in Medicare Part D.
How Do We Know If Our Prescription Benefit is “Creditable?
A prescription drug plan is considered “creditable” if the prescription drug benefits are expected to pay as much as or more than standard Medicare Part D prescription drug coverage. If a plan will not pay out as much as Medicare prescription drug plans pay, it is considered “non-creditable.” If you are a Vita Benefits Group client, you can confirm the creditability of your own plan by referring to your ERISA Welfare Plan Summary Plan Description (SPD).
Employer Action: Next Steps
The ERISA SPD that Vita provides for your welfare plans has been designed to incorporate all of the necessary disclosure language for the Medicare Part D Creditability requirement. If you have distributed this SPD to your employees in 2014 (or within the past 12 months looking back from October 15th, 2014), you are already in compliance with the annual disclosure requirement. If you have not already distributed the latest SPD, now would be a good time to do so!
If you prefer to send a separate Medicare Part D creditability notice, you may use the sample document that is available under the Employer Guides and Resources section of our website:
There you will find sample documents for plans that are creditable or non-creditable for Medicare Part D purposes. Please note that the vast majority of group health plans include prescription benefits that are creditable.
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