October Deadline: Medicare Part D Notices

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Every fall, employers that offer prescription drug coverage must send a federal notice. Many miss it because it is small, it comes every year, and it is easy to assume a broker or carrier handled it. For the upcoming October 2026, it deserves a closer look. The deadline is only a few weeks away, and new federal rules make it more likely that some plans will change status.

What the Notice Is

The Medicare Part D creditable coverage notice tells Medicare-eligible individuals whether their prescription drug coverage is expected to pay, on average, at least as much as standard Medicare Part D coverage.

  • If it does, the coverage is creditable.
  • If it does not, the coverage is non-creditable.

Employees use this information to decide whether to enroll in Medicare Part D or stay on the employer plan. The notice is timed to arrive before Medicare’s annual enrollment period, which begins October 15.

The Deadline

According to CMS, the notice must be provided before October 15 each year. For 2026, that means you must deliver the notice by Wednesday, October 14, 2026.

The notice is also required at other times, including:

  • Before an individual’s initial Medicare Part D enrollment period
  • When an individual joins your plan
  • When your coverage changes from creditable to non-creditable, or the reverse
  • When an individual requests it

Which Employers Must Send It

The requirement applies to employers of all sizes that offer prescription drug coverage, whether the plan is fully insured or self-funded. Small employers, nonprofits, school districts, and municipalities are included. Company size does not create an exemption.

Who Should Receive It

Technically, the notice goes to Medicare-eligible individuals who are covered by, or eligible for, your prescription drug coverage. That can include:

  • Active employees age 65 or older
  • Spouses and dependents who are Medicare-eligible
  • Employees or dependents under 65 who qualify for Medicare because of a disability
  • Retirees and COBRA participants

Most employers cannot reliably identify every Medicare-eligible person, especially dependents. For that reason, many advisors, including Newfront, recommend sending the notice to all plan participants.

Why 2026 Is Different

Medicare’s drug benefit has become richer. For 2027, standard Part D coverage has a $700 deductible and a $2,400 annual out-of-pocket cap. Because the Medicare benchmark is stronger, employer plans have a higher bar to clear.

CMS has also changed how employers make the determination. For 2026 plan years, employers may use either the original simplified method or a revised version. Beginning in 2027, only the revised method may be used. Under the revised method, a plan must provide reasonable coverage for brand and generic drugs, provide reasonable pharmacy access, and be designed to pay at least 73% of participants’ prescription drug expenses. Plans that do not meet that test can still use an actuarial determination.

CMS also finalized an exemption for account-based arrangements, such as HRAs, FSAs, HSAs, and ICHRAs, beginning with 2027. Group health plans with prescription drug benefits must still provide the notice.

What this means in practice. High-deductible health plans are the most likely to fall short, particularly those where prescription drugs are subject to the full deductible. A plan that was creditable last year may not be creditable for 2027. Medicare-eligible individuals will rely on this October notice when they choose 2027 Part D coverage, so confirm your plan’s 2027 status with your carrier or advisor before you send it, if your 2027 plan design is final. Do not reuse last year’s notice without checking.

Why It Matters to Employees

The stakes for employees are real and permanent. If a Medicare-eligible individual goes 63 days or more without creditable drug coverage after their initial enrollment period, a late enrollment penalty applies when they eventually join Part D. The penalty is 1% of the national base beneficiary premium for each month without coverage, and it lasts for as long as the person has Medicare drug coverage.

For 2027, CMS set the base beneficiary premium at $41.33 per month. An employee who goes 20 months without creditable coverage would pay about $8 more every month for the rest of their life. An employee who relied on an incorrect “creditable” notice could end up in exactly that situation.

How to Deliver the Notice

  • Use the CMS model notices. CMS provides model creditable and non-creditable notices in English and Spanish on its creditable coverage page.
  • Choose a delivery method. The notice can be mailed, hand-delivered, or sent electronically to employees who have regular access to electronic systems as part of their jobs.
  • Be careful with enrollment packets. The notice can be included with open enrollment materials if it is prominent and conspicuous. If it is not on the first page, include a separate bolded box of at least 14-point font on the first page that tells readers where to find it, as Newfront explains.
  • Watch the calendar. If your open enrollment materials will go out after October 14, send the Part D notice separately.
  • Keep records. Document what was sent, to whom, when, and how.

The Second Deadline: Reporting to CMS

The employee notice is only half of the requirement. Employers must also report creditable status to CMS using the Online Disclosure to CMS Form:

  • Within 60 days after the start of each plan year. For calendar-year plans, the next filing is due by March 1, 2027.
  • Within 30 days after the prescription drug plan ends.
  • Within 30 days after any change in creditable status.

A Small Notice With Lasting Consequences

The creditable coverage notice takes little time to send, but an error can cost employees money for the rest of their lives. This year, with new rules and a stronger Medicare benchmark, confirming your plan’s status is worth the extra step.

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