Important Information Regarding the Medicare and Medicaid Disclosure Notice

Based upon this information provided by the Hays Companies, Orion Risk Management is forwarding critical information to our clients regarding new legislation that will effect employers. The Hays Companies have been kind enough to forward the following review of the new legislation:

“The Centers for Medicare and Medicaid Studies (CMS) has issued notice requiring all employers (regardless of size or whether you are self funded or fully insured) to go online and provide notification of Credible/Non-Credible Drug Coverage under the new Medicare Part D regulations by March 31, 2006."

Early this month, the Centers for Medicare and Medicaid Studies (CMS) issued Regulations for providing the required notice of an employer/plan sponsor's Medicare Part D Creditable/Non-Creditable Status. This Notice, which must be done on-line with CMS, is due by 3/31/06 for plan years ending in 2006. Details can be found on the CMS website. Information can also be found on the Hays Companies Client Community website.

The Disclosure Notice MUST be submitted on-line at the CMS website.

All employers/plan sponsors - self-funded or fully-insured - of all sizes must complete the Disclosure Notice for its plan(s). Plans that are either all creditable or all non-creditable can be covered under the same notice. If the employer/plan sponsor has some plans that are creditable and some that are not, separate notices must be done.

Filing Timeframes -

A. For plan years ending in 2006 - 3/31/2006
B. For 2007 and subsequent years - 60 days after the beginning date of the plan year for which the entity is providing disclosure to CMS - Probably should be part of the renewal activity
C. Within 30 days after termination of the plan
D. Within 30 days after any change in the creditable coverage status of the prescription drug plan.

If you need assistance with this requirement or a further explanation, you may contact one of our skilled Benefits Professionals at Orion Risk Management or you may visit us at our website at www.orionrisk.com.