2011 SEPTEMBER 26 MC PT D REPT REMINDER

* * IMPORTANT BULLETIN * *

To: All Group Health Clients

From: Greenberg & Associates Insurance

Date: September 26, 2011

Re: Part D Disclosure- IMPORTANT DATE CHANGE TO OCTOBER 15TH

This bulletin is a reminder to everyone that the Medicare Part D Creditable/Non-Creditable disclosure notices are due shortly. It is important to note, however, that the due date has been changed! Notices are now due prior to October 15th of each year.

You are NOT required to do the disclosure notice if you know beyond a shadow of a doubt that you have no Medicare eligible employees or dependents within your group. Even though you may be certain about your employee status, keep in mind to consider the status of dependents within your group who may be Medicare eligible; i.e. may be on Social Security Disability (a disabled child or spouse), or, may have a spouse that is 65 or older.

Therefore, the bottom-line is if you are not sure about whether you have any Medicare eligibles, Creditable or Non-Creditable Notices need to be provided to your employees by October 15th. The web address to download the updated Creditable/Non-Creditable forms reflecting the new Medicare Part D Enrollment dates is http://www.cms.hhs.gov/creditablecoverage. Following are the time-lines you will need to keep in mind for future reference:

TIMES WHEN CREDITABLE/NON-CREDITABLE NOTICES MUST BE MADE:

• Prior to Medicare Part D Annual Coordinated Election Period beginning October 15th
• Prior to an individual’s Initial Enrollment Period for Part D;
• Prior to the effective date of coverage for any Medicare eligible individual that joins the plan
• Whenever prescription drug coverage ends or changes so that it is NO LONGER creditable or BECOMES creditable; and
• Upon a beneficiary’s request
• Note: In guidance issued by CMS on 1/4/06, if the creditable/non-creditable disclosure notice is provided to ALL plan participants, CMS will consider the first two items above to be met. This guidance also states that “prior to” means that the beneficiary must have been provided the Disclosure Notice within the past 12 months.

TIMING OF DISCLOSURE REPORTING TO CMS:

• At a minimum, disclosure to CMS must be made at the following times:
• For plan years that END in 2007 and beyond, disclosure of creditable coverage status must be provided within 60 days after the beginning of the plan year for which the entity is providing the disclosure to CMS.
• Within 30 days after the termination of the prescription drug plan; and
• Within 30 days after any change in the creditable/non-creditable coverage status

Please don’t hesitate to contact us if you need any help, or have questions.

Sharon Greenberg and Adrienne Hutchins