Employers who sponsor group health plans
covering prescription drugs must provide an annual credible coverage
notice to participants who are eligible for Medicare Part D. This notice
must be provided each year prior to Medicare Part D's Annual
Coordinated Election Period. Previously, this Election Period started
November 15 and ran through December 31. The Affordable Care Act changed
this Election Period so that beginning in 2011 it now starts on October
15 and runs through December 7.
Because of the change to the Election
Period, an employer's annual Medicare Part D notice should be sent to
Medicare Part D eligible plan participants on or before October 14,
2011. Employers should also ensure that their Part D notices have been
updated to reflect the new Election Period. A copy of CMS' updated model
notices can be obtained here.