Health Plans: Spring Deadlines

The following is a brief reminder of upcoming notice deadlines for group heath plans.

Notice to Centers for Medicare and Medicaid Services

Employers who offer prescription drug coverage must inform the Centers for Medicare and Medicaid Services (CMS) by March 31, 2006 as to whether their drug coverage or noncreditable under Medicare. For a review of the simplified determination of “creditable”coverage, click here for Seyfarth Shaw’s June 2005 Management Alert on Creditable Coverage. Employers must complete an electronic disclosure form using the CMS Web site at http://www.cms.hhs.gov/CreditableCoverage. The disclosure form is linked as “Disclosure toCMS Form.” Employers are asked to complete the following information for each type of coverage they offer:

• The name, street address and telephone number of the employer sponsoring the plan;
• The employer's EIN;
• Type of coverage, which will be "group health plan";
• The number of different benefit options available (e.g, HMO, PPO, etc.);
• Whether each benefit option has creditable or noncreditable prescription drug coverage;
• The beginning and ending date of the plan year;
•  An estimate of the number of Part D eligible (Medicare) individuals covered by each optionas of the beginning of the plan year;
• The date the notices of creditable or noncreditable coverage were provided to Part Deligible individuals (or if provided over a range of dates, the last date it was provided), andif the status of coverage has changed, the date of the change
• The name, title and e-mail address of the authorized individual employee submitting theelectronic form, and the date the form is submitted.