Your Group Health Plan May Have One Lingering CCN Requirement - and the Deadline is Looming
As most Group Health Plans are likely already aware, they are required to notify the CMS every year as to whether their drug coverage is “creditable” or “non-creditable” for Medicare Part D purposes. This notice must be mailed to all Medicare Eligible plan participants annually before Oct 15.

However, in addition to the mailing , the CMS requires a separate online disclosure notification for the Plan, which must be completed electronically on the CMS website . The information collected by the disclosure includes:
  • Basic organization information (tax ID, address, etc.);
  • Creditable coverage status for all plan options offered to employees;
  • Date creditable coverage notices were mailed;
  • Number of Medicare Part D Eligible individuals expected to be covered by a plan option during the plan year (it is acceptable for this to be a "good faith" estimate);
  • Number of Medicare Part D Eligible individuals stated above who are expected to be covered through an Employer/Union Retiree Group Health Plan (i.e. the number above that are retired but not approved under the RDS program).

It is important to note that while there is not a published penalty for the Group Health Plan for non-compliance with this requirement, individuals may face late enrollment penalties. Therefore, it is highly recommended that you complete the mailing and disclosures. This disclosure should be done within 60 days after the start of the health plan year.

As always, Part D Advisors is happy to address any questions, comments or concerns about CCNs, the Retiree Drug Subsidy program or Medicare in general that may arise. Please don't hesitate to reach out at any time.

CMS May Force Part D Plans to Offer Real-Time Pricing Data
The Centers for Medicare & Medicaid Services (CMS) issued the second part of its annual Advance Notice governing Medicare Advantage (MA) and Part D plans. In it, the agency is proposing a requirement for plans to offer real-time pricing comparisons to members. 

Last year, CMS finalized a plan that requires Part D plan sponsors to make that available to providers beginning in 2021. If the new proposal is put in place, Part D plans would have to offer real-time drug pricing data to members in 2022. In addition, CMS has proposed allowing Part D plans to offer a second specialty drug tier on their formulary for “preferred” specialty medications, allowing for more options with lower cost sharing.  

The goal is to encourage Part D plan sponsors to either expand coverage of generics or to incentivize them to push members to use these lower-cost drugs. In MA, the goal is to include data that more effectively reflects how members feel about their plans...( continue reading )
Upcoming RDS Deadlines
(plan year end | recon. due date)
11/2018 | 03/02/2020
12/2018 | 03/31/2020
01/2019 | 04/30/2020
(plan year start | app. due date)
06/01/2020 | 03/02/2020
07/01/2020 | 04/01/2020
08/01/2020 | 05/04/2020

Part D Advisors is proud to offer the nation's only AICPA SOC certified Retiree Drug Subsidy support services.