The 2025 Annual Election Period (AEP) for Medicare Part D begins October 15, 2024 and ends December 7, 2024.
The Medicare Modernization Act provides access to prescription drug coverage to all Medicare-eligible persons under the new Medicare Part D. Your obligation as an employer is to provide all employees, retirees, and continuants with information about your organization’s prescription benefits by October 15, 2024. Employees will use that information to help them formulate their personal decision to determine whether or not they will enroll in Medicare Part D prescription coverage.
Employees will use that information to help them formulate their personal decision of whether or not they will enroll in Medicare Part D prescription coverage outside of the employer plan. This decision is critical as penalties apply when Part D is not timely in place.
Medical insurance carriers typically notify policyholders regarding the Creditable versus Non-Creditable status of the prescription coverage plan.
Please keep in mind that this determination is the employer's responsibility when the employer is the plan sponsor. If the carrier states that the health plan is non-creditable, the benefits may still be creditable if the employer has an HRA arrangement in place. The employer would have to override the carrier notice. Therefore, it is the employer's responsibility to examine all of the benefits that are being provided to determine the creditability of the prescription coverage. The carrier is only providing notification regarding the creditability of the coverage that the carrier provides.
To assist you in meeting your obligations, please see the following:
Summary of Medicare Prescription Drug Coverages Information regarding Medicare Part D – please feel free to distribute to employees.
Sample Personalized Employee Letters for Notification of Creditable and Non-Creditable Coverage
Note: The above Model Notices were issued for use on or after April 1, 2011 and are still current. Spanish versions are also available at: cms.gov/Medicare/Prescription-Drug-Coverage/CreditableCoverage/Model-Notice-Letters.html
Creditable Coverage Disclosure to Centers for Medicare and Medicaid Services (CMS)
Most entities that currently provide prescription drug coverage to Medicare Part D eligible individuals (including employees, dependents, continuees and those eligible for Medicare due to age or disability) must disclose to CMS whether or not the coverage is a creditable prescription drug coverage. The disclosure must be provided whether the entity is primary or secondary to Medicare. Group plan sponsors must complete the Creditable Coverage Disclosure to CMS Form online: cms.gov/Medicare/Prescription-Drug-Coverage/CreditableCoverage/CCDisclosureForm.html
Timing of Creditable Coverage Disclosure to CMS Form from Entity
The Disclosure to CMS Form must be submitted to CMS on an annual basis and upon any change that affects whether the drug coverage is creditable. At a minimum, the Disclosure to CMS Form must be provided at the following times:
For Plan Years that end in 2007 and beyond, the Disclosure to CMS Form must be provided within 60 days after the beginning date of the Plan Year for which the entity is providing the Disclosure to CMS Form;
Within 30 days after the termination of the prescription drug plan; and
Within 30 days after any change in the creditable coverage status of the prescription drug plan.
More detailed information can be found at the Centers for Medicare and Medicaid Services website, cms.gov and medicare.gov.
If you have any questions, please contact your dedicated Ascela Account Manager.
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