Last month, one of our Client Service leaders distributed reminders to our client-facing employee benefit teams of an important upcoming deadline. The memo was to remind us to make sure our benefit clients knew of their obligation around the Medicare Part D notice that a health plan sponsor must distribute to all Medicare-eligible individuals by October 15 of each year. She even provided a step-by-step handout and included a “how to” video for “Holmies” that are new to our organization.
Since it is an employer responsibility to distribute the notice, many of our competitors do not provide resources to help with this or other compliance obligations. At Holmes Murphy, we know the people we serve have other dates that matter…like that Saturday your family is responsible for supplying orange slices and sodas for the kids at the soccer game. So, we try and take on some of the burden by a) providing training on why the notice is necessary, b) designing a key compliance dates calendar for our clients, c) monitoring and preparing the notice with the latest federal content standards, d) conducting the Medicare actuarial attestation, and then e) distributing the notice through technology that powers our account service workflow.
Here are the top three questions we receive most often from employers on Medicare Part D Notices:
- Our company only offers a health plan for active employees. We do not offer a retiree health plan, so we are not required to distribute a Medicare Part D notice, correct? Nope…not true amigo. If your company provides prescription drug coverage under a group health plan, a notice from the plan sponsor is required. It must be furnished prior to October 15 to all Medicare-eligible individuals who are covered under, or eligible for, the health plan, including COBRA participants and their dependents.
- How do we know which of our plan participants are Medicare eligible? Since most employers do not track Medicare eligibility on all plan participants, the most common way is to distribute the notice electronically to all eligible employees and dependents. The required notice may be provided in annual enrollment materials, separate mailings, or electronically. Electronic distribution requires verbiage to inform participants they are responsible for sharing the notice to their Medicare-eligible dependents covered under the group plan.
- Why and how do we have to distribute this notice to plan participants and the CMS? Medicare Part D Prescription Drug coverage came about in 2003, and the Centers for Medicare & Medicaid Services (CMS) wanted to make sure those who were still working at age 65 had a way to adequately compare their employer-sponsored drug coverage to that offered through Medicare Part D. Coverage is deemed to be creditable when it is at least actuarially equivalent to Medicare’s standard Part D coverage and non-creditable when it is not. We help our clients with this actuarial attestation requirement, so they know which notice to distribute. Additionally, a plan sponsor must also disclose to CMS annually no more than 60 days after the beginning of each plan year (March 1 for January 1 plans) whether coverage is creditable or non-creditable.
Recently, we learned one of our clients got acquired by a global real estate firm. Their C-suite executive we worked closest with elected to retire and wind out all the company affairs. Prior to terminating the benefit plans, he shared this with our entire team: “What a joy it has been to work with you guys. You are without a doubt the best!!!! We will schedule a lunch soon to formally say thanks for being a wonderful partner.” This same executive tragically lost his 32-year-old son to a heart condition earlier in the year. All the members of our account team attended the funeral. At the receiving line, tears streamed down our faces as we each gave him a hug. We knew his faith and family would see him through this next chapter as a grandpa supporting the daughter-in-law and grandkids, survived by his son.
In my business development role at Holmes Murphy, I am often asked what we do differently from the brokerage or consulting firm we will replace. There is usually never enough time to convey…All the Small Things.
