Attention All Employers: Notice of Creditable Coverage Due by November 15

All employer health plans must provide notice to Part D Eligible individuals by November 15, 2005 regarding whether a plan’s prescription-drug coverage is “creditable” under Medicare. The Centers for Medicare & Medicaid Services (“CMS”) has issued promised guidance and model language for the new notices. The guidance also offers a simplified method of determining whether coverage is “creditable” for employers not seeking to qualify for the new Medicare Part D subsidy for retiree prescription drug coverage.