Human Resources
Medicare Part D Disclosure Reminder and a Tip for EGWPs

Medicare Part D Disclosure Reminder and a Tip for EGWPs


This Aon Hewitt bulletin is a reminder of an annual (and in limited instances, more frequently than annual) disclosure requirement applicable to most employers that provide prescription drug coverage to individuals who are Medicare Part D-eligible. This disclosure is not new and should have occurred each year since 2006. The disclosure applies regardless of whether an employer provides retiree prescription drug benefits.

For 2013 calendar year plans, the disclosure must occur no later than March 1, 2013. The annual disclosure must occur for any employer that provides prescription drug coverage to anyone who is Medicare Part D-eligible.

An employer that has been approved for the retiree drug subsidy (RDS) is exempt from filing the notice with the Centers for Medicare and Medicaid Services (CMS) with respect to those qualified covered retirees for whom the employer is claiming the RDS. For this group, the employer’s RDS application serves as the disclosure to CMS. As noted below, even if the employer is approved for RDS for some groups, the notice will be required for all groups other than those for which the employer is claiming the RDS. For example, an employer that applies for the RDS must still disclose this information for any active employee who is Part D-eligible.

Due to tax changes under the Patient Protection Affordable Care Act (Affordable Care Act), some employers that sponsor retiree prescription drug plans moved to a Medicare Part D employer group waiver plan (EGWP) in 2013 instead of applying for the RDS. An EGWP is a Part D plan and therefore, is not required to issue notices of creditable coverage or disclose the creditable status of the coverage to CMS. Employers should keep this in mind when gathering the data for the disclosure.

The Aon Hewitt bulletin below discusses:

  • How to complete the notification;
  • Who must complete the notification;
  • The content of the disclosure notificationThe deadline for completing the notification; and
  • The content of the disclosure notification.

Download Medicare Part D Disclosure Reminder and a Tip for EGWPs