Part D Penalty Question

SirLurkAlot

Expert
59
A potential client called me about getting Part D. They are 79 y.o. and have been on medicare since age 65 but never had Part D or creditable coverage. From what month and year do I begin to calculate the number of months for the 1% penalty? Is it January 2006, June 2006 or other? I seem to remember they extended enrollment the first year.
 
A potential client called me about getting Part D. They are 79 y.o. and have been on medicare since age 65 but never had Part D or creditable coverage. From what month and year do I begin to calculate the number of months for the 1% penalty? Is it January 2006, June 2006 or other? I seem to remember they extended enrollment the first year.

Without charging you a research fee, the answer appears to be 5/15/2006.

Supporting info:
Chapter 3 of the Medicare Prescription Drug Benefit Manual
At the beginning of the Part D program, there was an IEP for Part D for all current Medicare beneficiaries and individuals who became eligible for Medicare in January 2006 that began on November 15, 2005 and ended May 15, 2006.

Chapter 4:
10.1 - Determine the Period in Question
The Part D plan sponsor shall determine, at the time of enrollment, whether a beneficiary who enrolls in Medicare drug plan will have or had a break in creditable prescription drug coverage for a continuous period of 63 days or more anytime after they were first eligible to enroll in a Medicare prescription drug plan. The Part D plan sponsor shall first determine the appropriate period in question: (1) following Part D/Retiree Drug Subsidy (RDS) disenrollment as described below; (2) the end of the Part D Initial Enrollment Period (IEP); or (3) end of the subsequent IEP.

10.1.2 - End of the Part D Initial Enrollment Period
For individuals who did not have prior Part D plan or RDS enrollment and are not in their subsequent IEP, the period in question begins on the day following the beneficiary’s Part D IEP and ends on the day before the beneficiary’s enrollment becomes effective with the Part D plan sponsor.
Unless otherwise informed by CMS, a Part D plan sponsor shall assume that the last day of a beneficiary’s IEP is/was:
 May 15, 2006 for a beneficiary who was eligible for Medicare Part D in January 2006.
 
I would not attempt to calculate it exactly yourself, I would just give a ballpark number.
 
Thanks for responses! Plan on ball-parking but wanted to ballpark as close as possible. I had thought June 1 but researched and didn't find exact answer. May 15 would be odd given the first of month effectives but this is Part D and their is no shortage of screwed up rules\guidelines.

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Wow! Thanks DS4!
 
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