February 2, 2009

New Medicare Part-D Notices – Again?

The Centers for Medicare and Medicaid Services (“CMS”) is at it again.

CMS has modified the Medicare Part D Model Disclosure Notice(s) of Creditable and Non-Creditable coverage. In effect, CMS has dispensed with the personalized model notice, with the personalized information now contained in the Model Individual Creditable (and Non-Creditable) Disclosure Notice(s) – (Please see links provided below).

The new forms should be used on or after January 1, 2009. The personalized information need not be completed, but it is advisable to include the personalized information when a plan participant makes a request for the notice. The reason for this is when an individual requests a notice, it is most likely that the individual wants documentation of how long he or she has had creditable or non-creditable coverage. (Note: A customized notice can be provided in lieu of these model forms as long as all of the required content is included in the customized form).

These notices are available in both English and Spanish at the following CMS website links:


The information contained in this Benefit Beat is not intended to be legal, accounting, or other professional advice, nor are these comments directed to specific situations.

As required by U.S. Treasury rules, we inform you that, unless expressly stated otherwise, any U.S. federal tax advice contained in this Benefit Beat is not intended or written to be used, and cannot be used, by any person for the purpose of avoiding any penalties that may be imposed by the Internal Revenue Service.

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