Under the Affordable Care Act (ACA), the annual enrollment period for Medicare Part D, the retiree drug benefit, will start one month earlier than in the past. Effective this fall, the 2012 enrollment period opens October 15th, 2011, instead of November 15th. As a result, plan sponsors must now prepare and provide Notices of Credible Coverage earlier, prior to October 15th.
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Get Your Report Now!Under the Medicare Modernization Act (MMA), plan sponsors that provide prescription drug coverage to Medicare beneficiaries, including employer-sponsored health plans, are required to disclose to all Part D-eligible individuals who are covered under, or who could apply for, the plan's prescription drug coverage whether the coverage is "creditable prescription drug coverage" or not.
Plan sponsors are required to provide Notices of Creditable Coverage at the following times:
- By October 15 of 2011 and succeeding years so that it is received prior to the Medicare Part D Election Period, October 15 through December 7;
- Prior to an individual’s initial enrollment period for Part D;
- Prior to the effective date of coverage for any Medicare-eligible individual who joins the plan;
- Whenever prescription drug coverage ends or changes so that it is no longer creditable or becomes creditable; and
- Upon request from a beneficiary.
Note: "Prior to" means that the beneficiary was provided the notice within the past 12 months.
Plan sponsors should also determine if they have to modify their Notices to reflect the ACA change.