Benefits Compliance


Reminder to Distribute Medicare Part D Notices before October 15th this Year
Starting this year (2011) group health plan sponsors must provide Medicare Part D “creditable coverage” notices prior to October 15th, because the Medicare annual enrollment period for Part D (Prescription Drug coverage) has been changed to October 15 – December 7. Before 2011, the Medicare Part D annual enrollment period was November 15th – December 15, but the Affordable Care Act changed it to start October 15th. (See Leavitt’s June 1, 2011 Benefits Compliance Bulletin for additional details.) Most plan sponsors use the CMS Model Medicare Part D Notices of Creditable Coverage and Non-Creditable Coverage to notify affected plan participants. These Model notices have been amended to reflect the October 15th date. You can access them here.

Requirement to Post NLRB Notice of Employee Rights
As of November 14, 2011, most private sector employers are required to post a notice advising employees of their rights under the National Labor Relations Act. The 11-by-17-inch notice should be posted in a conspicuous place, where other notifications of workplace rights and employer rules and policies are posted.

Click here for a downloadable copy of the NLRB’s 11-x-17-inch version of the poster.

Click here for a link to the NLRB webpage that has a short explanation of the required poster and links to a two-page 8.5-x-11-inch version of the poster as well as the 11-x-17-inch version. Copies also are available from any of the agency’s regional offices. In addition, employers should publish the notice on an internal or external website if other personnel policies or workplace notices are posted there.