Affordable Care Act Changes Timing of Medicare Part D Notices


Susan J. Freed

Employers who sponsor group health plans covering prescription drugs must provide an annual credible coverage notice to participants who are eligible for Medicare Part D. This notice must be provided each year prior to Medicare Part D’s Annual Coordinated Election Period. Previously, this Election Period started November 15 and ran through December 31. The Affordable Care Act changed this Election Period so that beginning in 2011 it now starts on October 15 and runs through December 7.

Because of the change to the Election Period, an employer’s annual Medicare Part D notice should be sent to Medicare Part D eligible plan participants on or before October 14, 2011. Employers should also ensure that their Part D notices have been updated to reflect the new Election Period. A copy of CMS’ updated model notices can be obtained at


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3 Responses to “Affordable Care Act Changes Timing of Medicare Part D Notices”

  1. Renee Blakely Says:

    Please confirm that employers can distribute the notice electronically via email and/or posting to an intranet site (provided all employees have access to the site.)

    • Susan Freed Says:

      Yes, the employer can deliver the notices electronically via email provided the employer follows the DOL requirements of electronic delivery and the Part D eligible participants have access to the employer’s electronic information system on a daily basis as part of their work duties or consent to the use of electronic delivery. If electronic delivery is used, the employer must also post the notice on its website or intranet site. Both email delivery and posting to an intranet or website are required if the employer is going to use electronic delivery. Please contact me if you have any additional questions, (515) 288-2500. Thank you, Susan Freed.

  2. Renee Blakely Says:

    The new guidelines require that employers notify employees of their Med D rights by Oct. 14th. However, many groups, January 1 groups in particular, won’t have decisions made until after Oct. 14th. Once decisions are made, we verify with the carriers that plans are creditible or non-creditible in order to send the correct letter. Plus, there may be a carrier change which is another item we insert into the letter. What are your thoughts on this??

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