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Employers need to prepare for fourth quarter benefits deadlines

September 15, 2017

By Lori Stewart, SPHR®, SHRM-SCP, HCS, Partner, Human Resources Consulting

Medicare Part D notice – Oct. 14, 2017 deadline

The Medicare Part D notice of creditable or non-creditable drug coverage is to be distributed annually to Medicare-eligible plan participants. The employer, not the insurance company, must distribute the notice.

The Medicare Part D notice must be provided to all Medicare-eligible individuals who are covered under the employer’s prescription drug plan, regardless of whether the plan pays primary or secondary to Medicare.

This notice must come from the employer, regardless of insured/self-insured status, employer size or grandfathered status. If the employer does not have a prescription drug plan, then no notice needs to be given. Many prescription drug plans are part of the overall health plan, and those types of drug plans also are required to give notice. The notice needs to be given annually, before the mid-October deadline. Eligible individuals who are considering purchasing Medicare Part D prescription drug coverage will be awarded a discounted premium if they can show their enrollment in a creditable plan within 63 days prior to their Medicare Part D enrollment. The Medicare Part D annual enrollment period runs from October 15 to December 7 each year.

Here are two helpful links to help employers comply with the Medicare Part D notice requirement:

CMS defines “creditable” coverage in this link. Bronze, silver, gold and platinum Affordable Care Act (ACA) plans qualify as creditable coverage, as do other plans, per the CMS definition.

Most current CMS model notices (template) for creditable (or non-creditable) coverage.

 

Transitional reinsurance fee Nov. 15, 2017 deadline and last payment ever

Who must pay this fee?

Self-insured health plans and plans with an HRA (health reimbursement account) integrated with a fully insured health plan are responsible for this fee. The insurance company will pay the fee for the fully insured plan, however the employer must pay the fee for the affiliated HRA. Health savings accounts (HSAs) and flex savings accounts (FSAs) are not subject to this fee.

For those plans affected, the second installment of $5.40 per member per year (PMPY) is due based on the covered lives count from the 2016 plan year. This is the last payment for the Transitional Reinsurance Fee Program unless Congress legislates something new, which is not probable at this time.

Employers had the choice to pay the $27 PMPY 2016 fee in one lump sum or to pay in two installments. Employers that remitted the full $27 PMPY fee before Jan. 17, 2017, do not need to remit in November. Employers that remitted just $21.60 PMPY on Jan. 17, 2017, are required to make this second installment of $5.40 PMPY due by Nov.15, 2017.

Here is a link to complete the form and pay the IRS:

https://www.pay.gov/public/form/start/77704988

If you need assistance or have questions about the fourth quarter deadlines, please contact 888.556.0123 or email hrconsulting@hkpayroll.com.

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