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Are any of your Medicare-eligible clients covered by non-creditable prescription drug coverage?
If they are enrolled in non-creditable coverage for more than 63-days, they may incur higher premiums when they eventually enroll in Medicare prescription drug coverage (such as a Part D plan or a Medicare Advantage plan that offers prescription drug coverage).
Their premium will increase by one percent each month over what they otherwise would have paid for each month without creditable coverage. It’s important to know if you have clients in this situation and to apprise them of their options. Here is an example of how a small change by the carrier, that caught us by surprise, would have triggered this penalty and how we were able to resolve it.
The client is Medicare-eligible (66 years old), but not enrolled in Medicare and during 2016 was covered through his company’s small group, high-deductible, HSA-compatible plan (the “Plan”) which had creditable coverage. His company’s renewal was January 1, 2017 and he elected to stay with his current plan. Here’s the tricky part: for 2017, the carrier tweaked the plan and the prescription drug benefit changed from being creditable to being non-creditable on January 1st. The carrier did disclose it….on page 43 of a 56 page renewal packet.
When we became aware of this, 53 days had elapsed. We immediately petitioned the carrier to grant this individual a waiver allowing him to change to a plan with creditable coverage retro to January 1st. They approved the petition. The benefits were that the client had no gap of creditable coverage and does not risk higher premiums when he eventually enrolls in a Medicare prescription drug plan. Of course, if we had known that the client’s plan had become non-creditable, we (Claremont and the broker) would have advised him to switch to a creditable plan at renewal.
To ensure you and your clients are not unpleasantly surprised, we recommend you:
2017 Plans with Non-Creditable Coverage from carriers represented by Claremont Insurance Services (as of 2/28/17):
Blue Shield of California
Covered California for Small Business
*Non-Creditable if Sharp is secondary payer to Medicare.
There may be a more recent answer to this question. Contact Claremont for an update.