Medicare Part D Notices and CMS Reporting Employer Requirements

Dear Valued QualChoice Client,

Subsidized prescription drug coverage became available to Medicare beneficiaries in 2006 through the Medicare Part D program. Under the Medicare Part D program, there are certain requirements placed on employers that provide prescription drug coverage to retirees and/or to Medicare-eligible individuals. As a courtesy reminder from QualChoice, this communication is intended to provide you with information about those obligations. The employer’s obligations are:

  1. Determine whether your prescription drug plan is “creditable coverage,” that is, the coverage is expected to pay on average as much as the standard prescription drug coverage under Medicare Part D.

    QualChoice has determined that, based on the information available as of the date of this communication, most health plans that include prescription drug coverage administered by QualChoice are “creditable coverage”.

    However, the prescription drug coverage in the following plan(s) is not "creditable coverage," but only when it is a family policy AND Medicare coverage is primary:

    ARP0265, ARQ0032, ARP2125, ARP2137, ARP0292, ARP0240, ARP2122, ARP0233

    Furthermore, the prescription drug coverage in the following plan(s) is not "creditable coverage," but only when Medicare coverage is primary:

    ARPB203, ARPB303, ARQB203, ARQB303

    Our records show that you do not offer any of the above plans.

    Once you have determined whether your organization’s prescription drug plan is “creditable coverage,” you must notify your Medicare-eligible members before October 15 each year whether your prescription drug coverage is or is not “creditable coverage.”A Medicare Part D-eligible member is someone: (i) that is entitled to Medicare benefits under Part A or enrolled in Medicare Part B and (ii) who lives in the service area of a Part D plan.

    If the coverage is creditable, you should notify your Medicare-eligible members of your determination by mailing the CMS model notice titled “Model Individual Creditable Coverage Disclosure Notice Language” to them. You will need to insert the name of your organization in the spaces provided. You can obtain an electronic version of this CMS model notice directly from the CMS website:
    https://www.cms.gov/Medicare/Prescription-Drug-Coverage/CreditableCoverage/Downloads/ModelCreditableCoverageDisclosureNotice051711.pdf

  2. You must also notify CMS annually of your determination of whether your prescription drug plan is “creditable coverage.” This notification should be done electronically through CMS’s web site. The link to the web registration on CMS’s web site can be found at:
    https://www.cms.gov/Medicare/Prescription-Drug-Coverage/CreditableCoverage/CCDisclosureForm.html

The CMS website contains additional information and guidance on determining whether you have creditable coverage and your obligations as an employer.

We hope that this information has been helpful. For more about this courtesy notice, please contact your Broker or QualChoice Account Service Representative for additional help.

Sincerely,
Jamie Thomason signature
Jamie Thomason
Sales Operations Manager

The information in this letter is for informational purposes only and should not be considered legal advice. If you have questions about your obligations under Medicare Part D, you should consult your attorney.

QCA22-AR-H-211