Medicare Part D Enrollment Period Shifts, Requiring Employers to Issue Notice a Month Earlier

The Affordable Care Act shifted the annual enrollment period for Medicare Part D a month to October 15th through December 7th. Prior to the change, annual enrollment began on November 15th.

CMS guidance, issued in 2009, provided that plans must provide Notices of Creditable (or Non-Creditable) Coverage at the following times:

• Prior to the Medicare annual enrollment period (which period the Affordable Care Act moved up a month earlier),

• Prior to an individual’s initial opportunity to enroll in Part D...

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