Failure to Provide Medicare Part D Notice of (Non)Creditable Coverage

[Chaz]

Has CMS ever promulgated any fines or penalties to be assessed against plan sponsors who fail to provide the Medicare Part D Notices of Creditable or Noncreditable Coverage to active employees (who are otherwise entitled to a notice)?

I can't seem to find anything on the wonderful thing that is the CMS website.

Thanks.

[Chaz]

Does anyone have any thoughts on this?

[J Simmons]

I don't know of any CMS penalty, but the employer could be opening itself up to liability to an affected employee who might enroll in Part D at first opportunity to avoid later cost increase, and want reimbursed for paying for duplicative cost when later learning that enrolling at first opportunity was not necessary.