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6
LEGAL DISCLAIMER:
Information contained in this publication is not legal advice, and
should not be construed as legal advice. If you need legal advice upon which you can rely,
you should seek a legal opinion from your attorney.
The DOL released new model Notices healthcare
plans can use to explain the
changes. The new model
General COBRA Notice is used for qualifying events
occurring after the December 19, 2009 and the new premium assistance notice is
used for other groups and is generally due to be distributed by February 17, 2010.
The COBRA subsidy extension and Notices are discussed in detail, including copies
of the model notices and other information and Q&As in Special Bulletin 2009-65,
Creditable Coverage Disclosure to CMS (60th day of Plan Year)
Healthcare plans that provide prescription drug coverage to Medicare Part D eligible
individuals must disclose to the Centers for Medicare and Medicaid Services (CMS)
whether the coverage is "creditable prescription drug coverage."
This disclosure to CMS is required whether the entity's coverage is primary or
secondary to Medicare. The Disclosure to CMS Form is due no later than 60
days following the beginning of the healthcare
plan’s plan year
(renewal
year, contract year, filing year, etc.). That would be March 1, 2010 for calendar
year plans, etc.
If a healthcare plan does not offer prescription drug benefits to any Medicare Part D
eligible individuals on the beginning date of their plan year (renewal year, contract
year, etc.), the plan is not required to complete the disclosure to CMS form for that
plan year.
Entities must
use the online Creditable Coverage Disclosure Form to disclose its
creditable coverage status to CMS. The Form and helpful information can be found
at: Disclosure to CMS Guidance and Instructions at:
The website has the Disclosure to CMS Form, Creditable Coverage Disclosure to
CMS Guidance and Creditable Coverage Disclosure to CMS Form Instructions and
Screen Shots and other helpful links and information.
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Tip: To review the past year’s benefit news,
access our Resources Page at:
which lists all
Research Publications by year beginning with
2004 with links to each publication
issued in that
year. The 2010 Topical Index of publications is available at: