Participant disclosure

Creditable coverage is expected to pay, on average, at least as much as standard Medicare Part D coverage. A written creditable or non-creditable coverage notice must generally reach Medicare-eligible individuals before October 15 each year and at other required times, including when an eligible individual joins the plan.

Who may need the notice

• Medicare-eligible active employees and covered dependents.
• Medicare-eligible COBRA qualified beneficiaries.
• Covered retirees and dependents.
• Individuals eligible for Medicare because of age, disability, or end-stage renal disease.

Because employers may not know every person’s Medicare eligibility, many sponsors distribute the notice broadly to everyone enrolled in prescription drug coverage.

Separate CMS disclosure

The plan sponsor generally completes CMS’s online disclosure within 60 days after the beginning of the plan year, within 30 days after prescription drug coverage terminates, and within 30 days after creditable status changes.

Operational control

1. Obtain the annual actuarial or simplified-determination result for each option.
2. Select the correct CMS model notice and tailor only as appropriate.
3. Map the population and delivery method.
4. Retain the notice, recipient logic, delivery evidence, and CMS confirmation.
5. Reissue and redisclose when coverage status changes.