Employer Changes to Medicare Part D

For those of you not familiar with Medicare Part D it is a federal program to subsidize the costs of prescription drugs for Medicare beneficiaries. It was enacted as part of the Medicare Prescription Drug, Improvement, and Modernization Act of 2003 (MMA) and went into effect on January 1, 2006.
Up until this year employers were responsible for communicating to employees who had reached Medicare eligibility, in other words age 65, the specifics of the Part D. This communication had to be done prior to November 15th because the enrollment period for their first year of eligibility ran from November 15th through December 31st. The communication had to consist of information provided by insurance carriers that explained whether the group health plan’s coverage is “creditable” (i.e., whether it is at least actuarially equivalent to the Medicare Part D coverage) or not. The information also had to point out that if someone opted not to take Part D coverage, but then later changed their mind there was a penalty in the form of an increased premium that was to be paid.
Well the timing of this communication has changed. According to the law firm of Fisher & Phillips “The annual Medicare Part D enrollment period has been moved to October 15 through December 7, beginning with enrollment for 2012. This change will require plan sponsors to update their Medicare Part D Notices of Creditable or Non-creditable Coverage and most likely will require plan sponsors to provide the notices to Medicare eligible participants by October 15 of this year.”
So you have been warned. Get with you insurance carrier and make sure they are providing you with the appropriate notices and information, assuming you have employees who qualify for Medicare.

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