Medicare Part D Notice Requirement: Employer Action Needed by October 14, 2026

If your organization offers prescription drug coverage to any Medicare-eligible individuals—employees, spouses, dependents, retirees, or COBRA participants—you have a required step to complete this fall.

What You Need to Do

Before October 14th, you must distribute a Medicare Part D Creditable Coverage Notice to any plan participant who is eligible for Medicare. This includes:

• Active employees age 65+ or any employee already enrolled in Medicare, regardless of their age
• Covered spouses or dependents who are Medicare-eligible
• Retirees or COBRA participants enrolled in your plan

Tip: To avoid missing anyone, we recommend sending the notice to all plan participants, regardless of their known Medicare status.

Why It Matters

This federally required notice tells individuals whether your plan’s prescription drug coverage is “creditable” or “non-creditable”—meaning whether it’s expected to pay at least as much as standard Medicare Part D.

• This action is mandatory. If you do not distribute the notice by the deadline, or you do not offer creditable coverage, affected individuals may face late enrollment penalties when they enroll in Medicare Part D in the future.
• The information assists eligible individuals to make an informed decision about whether and when to enroll in Medicare Part D, to avoid late enrollment penalties.
• Whether your plan is creditable is typically determined by the carrier (for fully insured plans) or a third-party administrator (for self-insured plans).

Your Compliance Checklist

1. Determine whether your coverage is creditable or non-creditable
2. Use the correct version of the CMS Model Notice (linked below)
3. Distribute the notice by October 14th
4. Remind employees to share the notice with Medicare-eligible dependents
5. Submit your online disclosure to CMS within 60 days of the start of your plan year

How to Distribute the Notice

You can distribute the notice in the following ways:

Option 1: Email (if the below criteria is met) 

• The employee regularly uses email as part of their job
• You notify them they’re responsible for sharing it with any covered dependents on Medicare

Option 2: Paper Delivery (hand or mail delivery) 

Option 3: Post on your Employee Portal 

How M&G Supports You

We’re here to help you stay compliant without the confusion. Our team provides:

• Help determining whether your coverage is creditable
• Editable CMS notice templates
• Annual compliance reminders to keep you on track

Helpful Resources

• CMS Model Notices (English & Spanish):
  https://www.cms.gov/Medicare/Prescription-Drug-Coverage/CreditableCoverage/Model-Notice-Letters.html

Questions?

Your M&G Employee Benefits Account Manager is happy to help.

Give us a call at 805-543-6887 if you need assistance or have questions about your plan’s status.

This information is general and is provided for educational purposes only. It is not intended to provide legal advice. You should not act on this information without consulting legal counsel or other knowledgeable advisors.