As a result of the change in the annual coordinated election period, the due date for providing notice of creditable coverage to participants and beneficiaries in health plans has changed from November 15 to October 15.

Action: Group health plans should provide the notices of creditable coverage prior to October 15, 2011.

Background

Medicare's rules require that entities offering prescription drug coverage provide notice to Medicare eligible participants and beneficiaries whether that coverage is creditable for Part D, including a notice before the beginning of the annual coordinated election period.¹ If the prescription drug coverage is creditable, an individual who delays enrolling in Part D will not be charged a higher premium for late enrollment. As a practical matter most group health plans send the notice to all participants because of the difficulty of identifying eligible spouses.

Prior to the passage of the Affordable Care Act, the creditable coverage notice was to be provided prior to November 15. The Affordable Care Act changed the beginning of the annual coordinated enrollment period for 2012 and future years from November 15 to October 15, thus moving up the deadline for providing notices.

Cheiron consultants can assist you in complying with the creditable coverage requirements.

¹42 CFR 423.56(c).