All employers who provide a prescription drug benefit to employees or dependents who are eligible for Medicare Part D are required to visit the Center for Medicare and Medicaid Services (CMS) website to disclose the creditability of their prescription drug benefit. The CMS requires that employers submit their disclosure on the CMS website within 60 days of the beginning of their ERISA plan year. Many employers have their ERISA plan year begin on January 1 and if this is the case for you then you must complete this online disclosure by February 29, 2012.
Here are a few helpful links to help with your compliance.
CMS Online Disclosure Form
Model Notice - Medicare Part D Notice - Creditable Coverage
Model Medicare Part D Notice - Non-Creditable Coverage
Most employers should distribute the Medicare Part D notice and complete the CMS Disclosure notice. The reason being that you, the employer, may not be aware that an employee or dependent is eligible for Medicare Part D. For example, an employee's dependent could be eligible for Medicare Part D because of their disability, age or medical condition such as end stage renal disease.
Employers should make every effort to ensure they are running a fully compliant health plan. This is simply one more step in the process.