Employer group health plans that include prescription coverage to Medicare eligible individuals must distribute a Notice of Creditable Coverage (or Noncreditable Coverage) each year on or before the Annual Election Period for Medicare. This year that date is October 15th. In the past it has been November 15th, so employers may not be aware of this change. These notices are important because if an individual does not maintain creditable coverage for a period of 63 days or longer following his or her initial enrollment period for Medicare Part D, then the individual will be subject to a late enrollment penalty.
An updated model notice is available at http://www.cms.gov/CreditableCoverage/
Shortly, insurance carrier will be sending employers notice on whether or not the prescription plan offered is considered creditable or not. Based on this information, employers will be required to provide the appropriate notice to employees by October 15th.