Medicare Part D and Creditable Coverage

Each year, employers who offer group health coverage must let their Medicare-eligible employees and their dependents know whether their prescription drug coverage through Sana is considered creditable (meets Medicare Part D’s standard) or non-creditable (does not meet Medicare Part D’s standard). 

The document that tells you whether your coverage is creditable or non-creditable is called the Medicare Part D Notice of Creditable (or Non-Creditable) Coverage. Sana prepares this notice every year and uploads it to the Documents section of your Sana Admin portal.

Important: Due to recent changes in Sana’s prescription drug coverage (such as an increased specialty drug copay), some Sana plans may now be considered non-creditable under Medicare Part D. The notice in your admin portal will tell you your plan’s status. It is possible that your group may have some creditable and some non-creditable plans. In this case, you will see both versions of the notice in your admin portal. 

What is Medicare Part D?

Medicare Part D is the federal program that helps cover the cost of prescription drugs for individuals who qualify for Medicare. 

Tip: Typically, Medicare-eligible employees are age 65 or older, but some people qualify earlier due to disability or other circumstances.

What does "creditable coverage" mean?

  • Creditable coverage: Your health plan is expected to pay, on average, at least as much as Medicare Part D would.

  • Non-creditable coverage: Your health plan is expected to pay less, on average, than Medicare Part D would.

Why it matters: This helps Medicare-eligible employees understand whether they may want to enroll in Medicare Part D. If they delay enrollment while covered by a non-creditable plan, they may face a permanent monthly late-enrollment penalty when they do enroll. The penalty is typically an extra 1% of the Part D premium for each month of delayed enrollment.

What employers need to do

Each September, Sana uploads your group’s Medicare Part D Notice of Creditable (or Non-Creditable) Coverage into the Documents section of your Sana Admin portal. Again, it is possible that your group may have a mix of some creditable and some non-creditable plans, and therefore, you will see both notices in your admin portal.

As a plan administrator, you must

  1. Review your group’s notice (or notices) in the Admin portal to confirm whether your prescription drug coverage is creditable or non-creditable.
  2. Distribute the notice to all Medicare-eligible employees and dependents by October 15 (the start of Medicare's annual enrollment period).
    • If you have both creditable and non-creditable plans, it will be easiest to let employees know they can find the notice applicable to their plan in the Documents section of their Sana Member portal.
    • This ensures that Medicare-eligible employees are aware of whether they may need to enroll in Medicare Part D to avoid penalties.
  1. Notify CMS (Centers for Medicare and Medicaid Services) of your plan’s creditability status within 60 days of your plan year’s start date.
    • Use CMS’s online disclosure form.
    • Based on your group’s notice, select the option that applies to your group:
      1. “All Options Offered Are Creditable”  
      2. “All Options Offered Are Non-Creditable” 
      3. “There are Some Creditable and Non-Creditable Options Offered

We know this stuff can be confusing! In summary:

  • Sana provides the notice in the Documents section of your admin portal.
  • You tell your Medicare-eligible employees to check their creditability status in the Documents section of their member portal.
  • You submit your group’s status to CMS.
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