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Creditable Coverage Notices

Employers are confused about which plan year needs to be addressed in the Medicare Part D creditable coverage notice, especially those employers who are trying to distribute a notice to eligible individuals by October 15 to align with Medicare's open enrollment period.

It is helpful to clarify that the creditable coverage notice is not technically required to be distributed in the fall if the employer is distributing it upon initial eligibility and during open enrollment each year.

CMS does require that the notice be distributed prior to October 15, but that requirement is met so long as it has been distributed within the 12 months prior to October 15.

If the notice is distributed during open enrollment each year, it makes it easier to address the creditable status for the upcoming plan year. However, if the notice is distributed in the early fall, or creditable status is not yet known during open enrollment, the best the employer can do is communicate the creditable status of the current plan. Then if creditable status changes upon the 2026 renewal, the employer would be obligated to send out an additional notice letting eligible individuals know that the creditable status of the plan has changed.

Medicare Part D Creditable Coverage Notice and Requirements Brief

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