Blue Access for Producers

Now Available Online: Medicare Part D Creditable Coverage Disclosure Requirement Reminder Notice

Each year, employers and unions who sponsor group health plans that include prescription drug coverage are required to notify Medicare-eligible individuals whether the prescription coverage offered is creditable or non-creditable to Medicare Part D prescription drug coverage. "Creditable" coverage means that the coverage is expected to pay on average as much as the standard Medicare Part D prescription drug coverage.

(NOTE: This notification to Medicare-eligibles enrolled in the group health plan is the responsibility of the employer, and Blue Cross and Blue Shield of New Mexico (BCBSNM) does not mail the Medicare Part D creditable coverage notices to the covered health plan participants.)

In order to be environmentally responsible, BCBSNM does not mail employers a reminder about their obligation to provide Medicare-eligible individuals the annual Medicare Part D Creditable Coverage notice. Instead, a Creditable Coverage letter has been posted in the secure Blue Access for EmployersSM (BAE) and Blue Access for Producers (BAP) portals, to assist you in determining your creditable coverage status. Producers can access the letter by logging in to BAP and clicking on "News and Updates."

The reminder letter will clarify the employer's notification responsibilities and include information that is necessary to determine whether or not the prescription drug coverage offered to those who are Medicare-eligible is creditable or non-creditable to Medicare Part D prescription drug coverage. An accompanying rate table will help to identify benefit designs that are estimated to satisfy Creditable Coverage using the CMS gross value test.

The second disclosure requirement is for employers who sponsor group health plan for Medicare-eligible individuals to complete the Online Disclosure to CMS Form to report the creditable coverage status of their prescription drug plan. The Disclosure should be completed annually no later than 60 days from the beginning of a plan year (contract year, renewal year), within 30 days after termination of a prescription drug plan, or within 30 days after any change in creditable coverage status. This disclosure requirement is the employer's responsibility and BCBSNM will not notify CMS of the employer's Creditable Coverage status.

This information contained in the creditable coverage reminder letter should not be construed as legal or actuarial advice.

You are urged to consult your own independent legal, actuarial and other advisors.

Please contact your BCBSNM representative with any questions.