Medicare Part D Creditable Coverage Certificates to Employees

It is that time of the year again when the annual Notice of Creditable Coverage as required under Medicare Part D must be distributed by Employers. The notice informs participants if the prescription drug coverage offered under the Employer's group health plan is considered "creditable" or "non-creditable" coverage. Employers who sponsor a health plan that includes prescription drug benefits must provide the annual notice to all Medicare-eligible participants. The notice will explain whether or not the prescription drug benefits offered under the group health plan are at least as good as the benefits offered under the Medicare Part D plan. The Notice of Credible Coverage must be provided: At least once a year before October 15th (the start of the annual Medicare Part D enrollment period which is from October 15th through December 7th for 2019). Whenever a Medicare-eligible employee, spouse or dependent enrolls in the employer's health plan (including Medicare eligible COBRA individuals and their dependents; Medicare eligible disabled individuals covered under the group health plan's prescription drug plan and any retirees and their dependents). Whenever there is a change in the creditable or non-creditable status of the employer's health plan prescription drug coverage. Whenever an individual requests the notice. CMS (The Centers for Medicare and Medicaid Services) has posted forms and instructions for providing this notice. Forms are available in English and Spanish. To access more information on this subject, please click on the link below: https://www.cms.gov/CreditableCoverage/ To access the notices, please click on the link below: https://www.cms.gov/Medicare/Prescription-Drug-Coverage/CreditableCoverage/CCDisclosureForm.html

Important Note for Employers! Employers must provide a disclosure to CMS on an annual basis, via an online form, reporting whether their prescription drug coverage is creditable or non-creditable. CMS requires that the disclosure be provided within: 60 days after the beginning date of the Plan Year for which the entity is providing the Disclosure to CMS Form; 30 days after the termination of the prescription drug plan; and 30 days after any change in the creditable coverage status of the prescription drug plan. Information regarding the Employer's Disclosure to CMS can be found by clicking on the link below: https://www.cms.gov/medicare/prescription-drug-coverage/creditablecoverage/ccdisclosureform.html

House Passes Bill Enhancing HSA's

H.R. 6311, renamed the Increasing Access to Lower Premium Plans and Expanding Health Savings Accounts Act and passed 242-176, would allow the ACA's premium tax credit for low and moderate earners to be applied when buying lower-premium, "catastrophic" copper plans; let people over age 30 buy copper plans; and allow copper and bronze-level individual and small-group market plans to qualify for HSA contributions. The bill also would make these modifications to tax-advantaged accounts:

• Raise HSA contributions to $6,650 for individuals and $13,300 for families, which is the combined annual limit on out-of-pocket and deductible expenses under an HSA-qualified insurance plan in 2018. Currently, for 2018, HSA contribution limits are $3,450 for individuals and $6,900 for those covered under family medical plans.

• Permit HSAs to pay for qualified medical expenses as of the start of HDHP coverage if the accounts are opened within 60 days after coverage under a HDHP begins.

• Allow working seniors participating in Medicare Part A and covered by a qualifying HDHP to contribute to an HSA.

• Permit spouses over the age of 55 to make an annual catch-up contribution (an extra $1,000) to an HSA that's linked to a health plan providing family coverage. Currently, only the account holder can make an annual catch-up contribution.

• At an employer's discretion, allow employees with an FSA or a health reimbursement arrangement (HRA) who enroll in a qualifying high-deductible health plan with an HSA to transfer balances from their FSA or HRA to the HSA. Transfers would be capped at $2,650 for individuals and $5,300 for families.

• Permit health FSA balances to be carried over to the following plan year. This rollover could not exceed three times the annual FSA contribution limit.

Excerpt from SHRM Article Dated 7-27-18 by Stephen Miller, CEBS