If your organization includes prescription coverage, The Medicare Modernization Act (MMA) requires you to notify Medicare-eligible policy holders whether their prescription plan coverage is creditable coverage. (This means the coverage is expected to pay, on average, as much as the standard Medicare prescription drug coverage.) There are two disclosure requirements. The first requires employers to provide a written disclosure prior to October 15th to all Medicare-eligible individuals covered under its prescription plan. The second, for employers with a calendar-year plan, requires completion of the on-line disclosure prior to March 1st. The disclosure, submitted to the Centers for Medicare and Medicaid Services (CMS), must report whether the coverage is “creditable”, meaning the coverage is expected to pay, on average, as much as the standard Medicare prescription drug coverage.
Employers offering creditable coverage via a non-calendar-year plan must also comply with the disclosure requirement. This must be done within 60 days of the beginning of the plan year. More information about Creditable Coverage is available here.