The annual Medicare Part D enrollment period has been moved to October 15 through December 7, beginning with enrollment for 2012. This change will require plan sponsors to update their Medicare Part D Notices of Creditable or Non-creditable Coverage and most likely will require plan sponsors to provide the notices to Medicare eligible participants by October 15 of this year.

Background

The Medicare Prescription Drug, Improvement, and Modernization Act of 2003 requires group health plans that provide prescription drug coverage to disclose to individuals eligible for Medicare Part D whether the plan's coverage is "creditable" (i.e., whether it is at least actuarially equivalent to the Medicare Part D coverage) or not.