STATE OF CONNECTICUT
NANCY WYMAN COMPTROLLER	OFFICE OF THE STATE COMPTROLLER 55 ELM STREET HARTFORD, CONNECTICUT 06106-1775	MARK OJAKIAN DEPUTY COMPTROLLER

MEMORANDUM 2005-39

November 16, 2005

TO THE HEADS OF ALL STATE AGENCIES

I.INTRODUCTION

The Medicare Prescription Drug, Improvement, and Modernization Act of 2003 (MMA) added a new prescription drug program to Medicare, referred to as "Part D" of Medicare. Prescription drug coverage under Medicare will be available starting January 1, 2006. This new program requires that the State, as an entity that provides prescription drug coverage to Medicare beneficiaries, must disclose whether the entity's coverage is "creditable prescription drug coverage" (Disclosure Notice). The disclosure is required whether the entity's coverage is primary or secondary to Medicare. The Creditable Coverage Disclosure Notice (hereinafter the "Notice") must be provided to all Part D eligible individuals who are covered under, or who apply for, the State's prescription drug coverage. The Notice requirement applies with respect to Medicare beneficiaries who are active employees and those who are retired, as well as to Medicare beneficiaries who are covered as spouses under active or retiree coverage.

The prescription drug benefits of the State employee and retiree health plan qualify as creditable coverage, meaning that the benefits provided are at least as valuable as the benefits provided under Medicare Part D.

The Retirement and Benefits Services Division mailed the Notice to retired employees and beneficiaries with the October 2005 Retirement check, and will provide such Notices to Retirees in the future. The Division has also mailed the Notice to all active employees and their spouses who are, or will be, age 65 on or before January 1, 2007. 

In that connection, the purpose of this Memorandum is to notify state agencies of the procedures that are being implemented to assure that all Medicare eligible employees and their dependents are provided the Notice as required by federal law, and the tasks that must be performed at the Agency level to identify those eligible for such Notice.

A. Recordkeeping - In order to assure compliance with federal regulations that require employers to provide the Notice at certain times as outlined in B. below, the following information must be obtained from all Medicare beneficiaries prior to the issuance of the Notice in B. below:

1. Social Security Number and Date of Birth - Note that these items are already required for benefit administration purposes.
2. Date of Medicare Enrollment - Request a copy of the beneficiaries Medicare Card. Note that there may be different dates for Medicare Part A and Part B.

The information must be entered into the CORE-CT Personal Data page (for employees), or on the Dependent\Beneficiary page, Medicare Flag tab, for dependent\beneficiaries.

B. Notice is also required at certain other times, and must be provided by the employing Agency as follows:

1. Prior to the effective date of coverage for any beneficiary when they first enroll in state employee health coverage. This will include the following Medicare-eligible beneficiaries: a. new hires; b. current employees who enroll in coverage due to a loss of coverage from another source; and c. dependents who are enrolled in coverage as a result of marriage\civil union.
2. Prior to an individual beneficiary's Initial Enrollment Period for Medicare D. This is the period prior to the beneficiary's 65th birthday, or upon eligibility for Medicare based on ESRD (End Stage Renal Disease) or disability.
3. Upon termination of state employee health coverage. Agencies must routinely provide the Notice to Medicare beneficiaries at the same time as they issue the COBRA Continuation Coverage Notice.
4. At any other time upon request by a Medicare Beneficiary

C. Use the form letter Creditable Coverage Notice_EE_form.doc (enclosed) in the above situations. Complete all fields in the form letter, and a place a copy of the Notice in the employee's personnel file used. The text of this letter cannot be changed by the Agency.

III. QUESTIONS

Inquiries from employees who have questions about Medicare D that are not answered in the Creditable Coverage Notice should be referred to Medicare. Inquiries from retired employees should be referred to the Retirement Health Insurance Unit at 702-3533. Personnel or Payroll staff who have questions concerning the Medicare D Creditable Coverage Notice should contact the Comptroller's Retirement & Benefit Services Division, Health Care Analysis Unit at (860) 702-3535.

Very truly yours,

Nancy Wyman
State Comptroller

NW/NM/WPM

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