Wednesday, January 22, 2014

Dec 1 Early Renewal Plans have Jan 29 Deadline to Notify CMS of Medicare Part D Notices

By Lisa Klinger

For small group plans that renewed early on December 1, 2013, the deadline for online notice to CMS regarding Medicare Part D creditable coverage and notices will be January 29, 2014, rather than March 1.

Health plan sponsors must notify the Centers for Medicare and Medicaid Services (CMS) within 60 days from the beginning of the plan or policy year as to whether their group health plan Prescription Drug coverage is “creditable coverage” under Medicare Part D. For calendar year plans, this deadline is March 1st. For small group plans that renewed early on December 1, 2013, however, the deadline will be 31 days earlier, which would be January 29, 2014. If a plan renewed early but kept its prior plan year, the CMS deadline will not change. For small plans that do not file Form 5500s and so do not specify a plan year, however, the contract date or renewal date will apply rather than the plan year. Thus, their CMS deadline will be January 29, 2014. This notice can only be made by using the Online Disclosure to CMS Form on the CMS website. See below for additional details. The website also requires the plan sponsor to report the date they sent the Medicare Part D notices to Medicare-eligible plan participants.

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