October 15 Deadline Approaching for Part D Notices

As a reminder, the deadline to distribute Part D notices is October 15, 2026.

This deadline applies to employers with group health plans that provide prescription drug coverage.

Medicare Part D Notices

Employers with group health plans that provide prescription drug coverage must notify Medicare Part D eligible individuals before October 15 of each year about whether the drug coverage is at least as good as the Medicare Part D coverage (in other words, whether their prescription drug coverage is “creditable”).

This notice is important because Medicare beneficiaries who are not covered by creditable prescription drug coverage and do not enroll in Medicare Part D when first eligible will likely pay higher premiums if they enroll at a later date.

The employer is ultimately responsible for providing these notices to the individuals.

• However, fully insured carriers typically provide the notices to the employer or the individuals. The broker and/or the employer should check with the carrier.
• For Level Funded plans, the employer is responsible for providing the notices. The broker and/or the employer should reach out to the administrator of the group health plan to verify.

Penalties for Noncompliance

Although there are no specific penalties associated with the Part D notice requirement, failing to provide the notice may have a negative impact on employee relations, especially if an individual later incurs a late enrollment penalty because they were unaware that their prescription drug coverage through their employer was not creditable.

In addition, employers who claim the Retiree Drug Subsidy will not qualify for the subsidy unless they provide these notices. Other federal laws may also indirectly provide consequences to a noncompliant employer.

Resources

• Final 2026 Part D Redesign Program Instructions | CMS
• Amwins Benefits Brief - Medicare Part D Creditable Coverage Notice & Reporting
• Amwins Benefits Compliance Library - Medicare Part D Creditable Coverage

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