Prior to the Medicare Part D Annual Coordinated Election Period beginning November 15^th each year;

1. Prior to an individual’s Initial Enrollment Period for Part D;
2. Prior to the effective date of coverage for any Medicare Eligible individual that joins the plan;
3. Whenever the employer no longer offers or the employer changes prescription drug coverage so that is no longer creditable or becomes creditable; and
4. Upon request by the beneficiary.

The Centers for Medicare and Medicaid Services (CMS) considers items 1 and 2 met if the creditable disclosure notice is provided to all plan participants prior to November 15^th of each year.  CMS has now provided guidance that “prior to” means that the individual must have been provided the disclosure notice within the past 12 months.

We are recommending that you send this notice to all covered members annually at the beginning of each November.  This eliminates the potential for overlooking someone who may be eligible that you are unaware of.

A template of the letter can be obtained from CMS at:  http://www.cms.hhs.gov/CreditableCoverage/09_CCafterJune15.asp#TopOfPage or Resources Page.  Please feel free to call our office for personalized assistance.

HOW TO LOG IN AND COMPLETE THE ONLINE FORM
In addition to notifying members, you are also required to report completion via the CMS Website.  This reporting requirement cannot be completed by the insurance company or provider.  The employer should:

Log into https://www.cms.hhs.gov/CreditableCoverage/45_CCDisclosureForm.asp

1. Follow the instructions.
2. One single disclosure form can be submitted for the entire employer, even if you have more than one medical plan.
3. For additional guidance and the most updated information, go to http://www.cms.hhs.gov/creditablecoverage

PLEASE NOTE

1. This is the sole method of complying with this federal guideline
2. It will only take a few minutes to complete
3. Employers must complete this form annually or upon any change in whether the medical plan’s prescription benefits are creditable coverage for Medicare Part D.

QUESTIONS?
For more information about how to determine is your prescription drug coverage is deemed to be creditable, this reporting requirement and the Creditable Coverage Notice requirements, you can find it at www.cms.hhs.gov or call Olympic Crest Insurance, Inc. at 800-644-2568.