There is an upcoming deadline for the employer disclosure notice requirement for Medicare Part D (the prescription drug program).


The deadline to distribute the notices is October 15, 2018


This notice should be distributed to all Part D eligible individuals who are covered under, or who apply for, the plan’s prescription drug coverage, regardless of whether the prescription drug coverage is primary or secondary to Medicare Part D. The Disclosure Notice requirement applies to Medicare beneficiaries who are active or retired employees, disabled, or on COBRA, as well as Medicare beneficiaries who are covered as a spouse or dependent. 


An individual is eligible for Medicare Part D if: 

1. The Individual is entitled to Medicare Prat A and is enrolled in Medicare Part B, as of the effective date of coverage under the Part D plan; and 

2. The individual resides in the service area of a prescription drug plan or of a Medicare Advantage plan that provides prescription drug coverage. 


Additional information and resources can be found HERE.


Step by Step Outline: 

STEP 1:  Assess Your Active Employee Population.

  • Determine who you are covering.
  • Could you potentially be covering an active employee that is Medicare eligible?
  • Could you potentially be covering an active employee’s spouse or dependent that is Medicare eligible?  (Note: Individuals under age 65 may be eligible for Medicare if they are disabled or have End Stage Renal Disease.)


STEP 2:  Determine Whether Your Prescription Drug Plan’s Coverage is Deemed to be Creditable.


STEP 3:  Develop and Implement an Annual Communication           

                Campaign for Active Employees.

  • Provide clear communications to all employees, human resources, and management staff. This notification needs to be done on an annual basis due to possible plan changes, new employees, and/or employees attaining the age of 65 within the past year.
  • Recommended Strategy: Notify all employees of the Creditable Coverage finding, regardless of age or dependent status, with a short cover letter explaining what Medicare Part D is and to whom it pertains. This can be done via email, internet, bulletin boards, payroll stuffers, etc.