Medicare Part D

Hunter1

[font size="1" color="#FF0000"]LAST EDITED ON 08-05-05 AT 11:54AM (CST)[/font][br][br]I'm just coming up to speed on this, so can someone help out?
Our health plan, which includes prescription drug coverage, does not include a mail order option. We only cover employees over the age of 65 if they continue to work. Sometimes, in addition, we will have a spouse on our plan who is older than 65 while the employee is still working.
First, it seems that we are going to have to notify Medicare eligible individuals of their coverage/options, etc, right? And, because our plan doesn't have a mail order option, will it not be 'creditable' coverage, even though our benefit plan is much richer than the Medicare plan?

Edit: To clarify: It seems that the ONLY part of the simplified creditable coverage test that our plan wouldn't meet if we do not apply for the subsidy is the optional mail-order requirement. (We have so few Medicare-eligible insureds that it wouldn't be cost effective for us to have the necessary actuarial study required for the subsidy.)

stilldazed

I don't have an answer for you, but I've done some reading on the subject this week, checked the CMS web page and didn't really find it to be helpful, and have placed a call to our carrier. If I find some information that I think is helpful, I'll let you know.

stilldazed

I still don't have an answer, but I do have a little more infor. Our health ins rep in our carrier's home office told me today that insurance carrier reps have just started receiving training from CMS within the last 2 to 4 weeks on the benefit. Our health insurance carrier is BCBS of Florida, a major carrier, and BCBS has not yet confirmed whether the Rx benefit on their health plans is creditable. Their current presumption is that it is, but Florida's insurance carriers probably won't begin the confirmation process for another month. What we are also being told as of today is that while CMS has specific verbiage for employers to use in the notice to employees, it is not yet available for review.

I read an article yesterday naming 2 or 3 major retail chains who had announced plans to add information kiosks within the next week near their Rx counters in an effort to begin to educate Medicare-eligible patrons. The article also described that that form of information dissemination at such a preliminary date by the retailers would be noncompliant in that it could be not begin until 10/15. The CMS web page makes several references to a huge marketing blitz to be initiated at that level to ensure Medicare-eligible consumers have appropriate information to make the correct decisions for themselves. Apparently, Medicare penalties for delayed enrollments in the benefits are expected to be sizable (as with other late Medicare enrollments), and a general fear may be who would assume responsibility for misinforming the public, especially if the misinformation caused someone to incur a penalty down the road.

Hunter1

Thanks for your help thus far. Our PBM is beginning to come up to speed on this - based at least in part on my request that they provide information, they promised to begin mailings to customers asap. They're supposedly the 4th largest PBM in the nation.

I do know (or at least I've read) that the penalty for individuals who do not sign up at the time they are eligible is 1% of the premium for each month they don't sign up. In other words, if the employer informed them that they had creditable coverage so the employee didn't sign up until, say 4 years later when they lost coverage through the employer's plan, and it turned out that the coverage they had wasn't creditable, the individual would pay a 48% (48 months) higher premium than if they had signed up when they were eligible.

stilldazed

Your penalty info is the same message we have been given so far as well--a significant enough penalty to the individual that no group health provider insurance company is interested in being the entity responsibility for a misunderstanding that forces a penalty situation.

Please post more info as you learn more. This issue will affect most all of us.

Thanks,

Gloria

Here are a few links from CMS site for:

==>Creditable Cover Guidance,

==>Model notice informing Medicare participants of creditable coverage and a

==>Model notice informing the Medicare participants of non-creditable prescription coverage.


[url]http://www.cms.hhs.gov/medicarereform/CCGuidance.pdf[/url]


[url]http://www.cms.hhs.gov/medicarereform/CredCov-BeneDsclsreNtc.pdf[/url]



[url]http://www.cms.hhs.gov/medicarereform/Non-CredCov-BeneDsclsreNtc.pdf[/url]


Pages 1, 2, 3 & 10 of the Creditable Cover Guidance also have additional links for publications, FAQs, etc.

Hope this will be helpful

G

stilldazed

Thanks for the making the info so easy to find. As it turns out, I just opened today's mail and have a questionnaire from our health provider related to this topic. They have definitely begun the process to determine creditability.

Thanks,

mushroomHR

After researching this topic and reading all the information, I am taking this to mean that an employer must only provide this notice to retirees who have attained age 65 and are receiving monthly social security benefits and also receiving retiree health coverage through their former employer. These notices would not have to be provided to employees 65 or over who are still working and are insured under the company's health plan. Is my interpretation correct or am I missing something? Thanks.

stilldazed

I still don't have a precise answer for your question either and actually think it represents where most of us are with this topic--confused!

I do know there is some sort of major educational/marketing blitz planned through CMS, so we'll probably all know in the near future. My understanding to date, however, is that the message must be confirmed to any Medicare-eligible participant. Based on that understanding, my next-level question to our reps has been whether that includes dependents who are also Medicare-eligible. So far, our reps have declined to answer that question as well.

Maybe another forumite has more insight.

mushroomHR

It is my understanding that we do have to send this notice to dependents who are Medicare eligible. My question is, how do we know this information? I don't have the birthdates of my employees' dependents. I think they are making this a huge burden for employers. It should be the responsibility of the insurer to send these notices out since they are the ones with the information about dependents and the prescription plan. Just my opinion.

stilldazed

My general sentiment is that at first glance things are not looking so good for employers in this instance. Regardless of my gut instinct (and as hard as it is proving to be today), I am trying very hard to maintain some level of optimism. My experience tells me that we (employers) may get notice from health carriers or CMS and will be required to follow through--of course with all the typical notification characteristics--short lead time, critical dead line, cleverly incripted coding, and the need to work staff overtime to ensure that the project (including all coding corrections) in on time. That's the current practice for MediCOB confirmations.

DMK

It is my understanding that dependents must be notified as well and it was suggested that we send a notice to the enployee ("and dependents") to their home. Our Highmark rep in PA said the insurance company is not responsible for determining credible coverage or for notifying the employees.

mushroomHR

I received information from our health carrier, UnitedHealthcare, and yes, we do have to send notifications to eligible employees and eligible dependents (how are we to know what dependents are eligible?). I will just send the notice to ALL employees. Our carrier also determined that our prescription plan is creditable coverage since it is better than Medicare Part D's coverage. I just received that information yesterday.

Another question I have is does anyone know where to find the information for the employer's 28% subsidy program and how to apply for it through CMS?