2011-6 - Medicare Part-D Annual Notices Due October 15

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The Patient Protection and Affordable Care Act of 2010 (PPACA) strikes again! As a part of this landmark legislation, Plan Sponsors with group health plans which include prescription drug benefits now must provide the annual Part-D Creditable Coverage Notice by October 15, 2011. Previously Plan Sponsors were to provide the notice no later than November 15, the first day of the Medicare Part-D open enrollment period. PPACA changed the Part-D open enrollment to be the period between October 15, 2011 and December 7, 2011. In addition, the Center for Medicare and Medicaid Services (CMS) published new model notices in early April, reflecting this change in open enrollment dates. The purpose of this Memorandum is to discuss the ramifications of these two events.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Ryan Lloyd | Attorney Advertising

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