September 2025 HR Newsletter | Forsite Benefits

Oct. 15 Deadline for Medicare Part D Coverage Notices

Employers must notify Medicare-eligible policyholders if their prescription drug coverage is credible or not.

The Medicare Modernization Act (MMA) requires entities (whose policies include prescription drug coverage) to notify Medicare-eligible policyholders whether their prescription drug coverage is creditable, (which means that the coverage is expected to pay, on average, as much as the standard Medicare prescription drug coverage) or non-creditable.

2025 brought significant change to the determination of credibility.

Starting 2025, CMS has reduced the maximum out-of-pocket on Medicare Part D plans from $8000 down to $2000. This change likely precludes most high deductible health plans (HDHPs) from qualifying as credible coverage. This means any individual covered under a group plan that is Medicare Part D eligible may face a penalty of 1% of the national base premium ($34.70 in 2024) times the number of uncovered months.

Example:

Mrs. Martinez has Medicare, and her first chance to get Medicare drug coverage (during her Initial Enrollment Period) ended on July 31, 2024. She doesn’t have credible prescription drug coverage from any other source. She didn’t join a Medicare drug plan by July 31, 2024 or during Open Enrollment in 2024, and instead will join during the Open Enrollment Period ending December 7, 2025. Her Medicare drug coverage will start January 1, 2026.

Since Mrs. Martinez was without creditable prescription drug coverage from August 2024–December 2025, her penalty in 2025 is 17% (1% for each of the 17 months) of $34.70 (the national base beneficiary premium) or $5.90 each month will be added to her Medicare Part D premium.

Here's the math:

17 (17% penalty) × $34.70 (Base beneficiary premium) = $5.90

$5.90 = Mrs. Martinez's monthly late enrollment penalty for 2026

Who Must Comply

The disclosure requirements apply generally to employers sponsoring group health plans that offer prescription drug coverage to Medicare-eligible individuals.

Model notices/templates

These model notices may be used to satisfy this requirement, issued by the Centers for Medicare & Medicaid Services.

Medicare Part D – Creditable Coverage Disclosure Notice Template - [View]
Non-Creditable Coverage Disclosure Notice Template - [View]

Information Required

Notifies Medicare-eligible individuals whether the plan's prescription drug coverage is creditable coverage, meaning the coverage is expected to pay, on average, as much as the standard Medicare prescription drug coverage.

Note: Individuals who do not maintain creditable coverage for 63 days or longer following their initial enrollment period for Medicare Part D may be required to pay a late enrollment penalty. Accordingly, this information is essential to the decision to enroll in a Medicare Part D prescription drug plan.

Who it must be provided to

Medicare-eligible active employees and their dependents
Medicare-eligible COBRA individuals and their dependents
Medicare-eligible disabled individuals covered under the prescription drug plan
Any retirees and their dependents

Who it must be provided by

Employers who sponsor group health plans that offer prescription drug coverage to Medicare-eligible individuals.

When it is Due

Prior to the annual enrollment period for Medicare Part D that begins on Oct. 15th
Prior to an individual's initial enrollment period for Medicare Part D
Prior to the effective date of enrolling in the employer's prescription drug plan and upon any change that affects whether the coverage is credible
Upon request by the individual

Online disclosure to the Centers for Medicare & Medicaid Services is also required annually, no later than 60 days from the beginning of a plan year, within 30 days after termination of a prescription drug plan, or within 30 days after any change in creditable coverage status.

[ VIEW ONLINE DISCLOSURE ]

[Upcoming Webinar] Building a Great Company Culture at Iowa Speciality

What if your culture was your strongest business strategy?

At Iowa Specialty Hospital, culture isn’t just a backdrop. It’s the driving force behind high retention, employee satisfaction, and organizational success.

In this webinar, you’ll learn how they made it happen—and how you can too.

You’ll hear directly from Steve Simonin, President & CEO of Iowa Specialty Hospitals & Clinics. A nationally recognized healthcare leader who has led his organization through nearly three decades of cultural and operational transformation. Under his leadership, Iowa Specialty has grown significantly, earning top honors for patient satisfaction and workforce engagement, year after year.

Joining him is Brooke Nerlien, a registered nurse, wellness coach, and diabetes educator with 16 years of experience. Brooke leads the wellness efforts at Iowa Specialty and brings a practical, human-centered perspective on building programs that actually work.

Together, they’ll share:

How culture became a foundational business strategy, on par with operations and growth.

What a connected, energized workplace really looks like in healthcare and beyond.
Leadership behaviors (like the “510 rule”) that foster belonging and build trust.
Tangible wellness strategies that support both physical and emotional wellbeing.
Results they’ve seen in employee satisfaction (96%!), retention, and national recognition.
How Motion Connected supports their vision—and why it’s working
What a connected, energized workplace really looks like in healthcare and beyond.
Leadership behaviors (like the “510 rule”) that foster belonging and build trust.
Tangible wellness strategies that support both physical and emotional wellbeing.
Results they’ve seen in employee satisfaction (96%!), retention, and national recognition.
How Motion Connected supports their vision—and why it’s working

Wednesday, September 10th
11:00 AM CST

REGISTER TODAY!

E-Verify Status Change Report Updated to Include Document Number

The U.S. Citizenship and Immigration Services recently announced that the Status Change Report will include an additional “Revoked Document Number” field to help employers determine whether an employee’s employment authorization document (EAD) presented when completing the Employment Eligibility Verification form (Form I-9) and used to create their E-Verify case is the revoked EAD in the report. If the EAD has been revoked, the employer must reverify the employee by completing Supplement B of Form I-9.

If an employer has a current employee who appears on the Status Change Report, the employer should compare the employee’s EAD card number used for Form I-9 to the Revoked Document Number field in the report to determine if the employer must reverify the employee’s employment authorization. For example, if the employee’s EAD used for Form I-9, which was used to create their E-Verify case, is the same number listed in the Revoked Document Number filed, then the employee’s EAD is revoked, and the employer must reverify the employee with a different acceptable List A or C document using Form I-9 Supplement B. However, if the employee’s EAD used for Form I-9 is different than the number listed in the Revoked Document Number field, the employee’s EAD is not revoked, and the employer does not need to reverify the employee’s employment authorization until the EAD expires.

Employer Takeaway

Employers should regularly generate the Status Change Report to identify E-Verify cases created with a revoked EAD and reverify each employee by completing Supplement B of Form I-9 if their EAD was revoked. Employees may still be employment authorized based on another status or provision of law and may provide other acceptable Form I-9 documentation to demonstrate employment authorization.

Employers can review the EAD Revocation Guidance for E-Verify Employers for more information about the Status Change Report.

Report: Filling Job Openings Remains a Challenge for Small Businesses

A recent report by the National Federation of Independent Businesses (NFIB) found that 36% (seasonally adjusted) of small business owners reported having job openings they could not fill in June 2025.

The ongoing labor shortage continues to disrupt business operations and prevent growth. However, despite the challenging hiring environment, small businesses can adjust their attraction strategies to remain competitive and win over talent.

According to the report, 58% of small business owners were hiring or trying to hire, but 50% of those reported few or no qualified applicants.

Tips for Navigating Hiring Challenges

Consider the following tips for navigating hiring challenges as a small business:

Improve job descriptions. A well-crafted job description can make a significant difference in attracting candidates. Be specific about the skills and responsibilities required, and use clear, engaging language. Highlight what makes your business unique, such as your company culture, mission, and growth opportunities, to help applicants envision themselves as part of your team.

Offer competitive benefits. Compensation is always one of the most critical factors in employment decisions. Unfortunately, many small businesses have limited budgets to compete against larger employers. If budget constraints limit salary increases, consider offering valuable nonmonetary benefits like flexible scheduling, employee discounts or wellness programs to boost appeal.

Invest in learning and development. Hiring candidates with potential and providing on-the-job training can be a smart strategy when qualified applicants are scarce. Develop internal training programs or collaborate with local colleges and trade schools to create internships or apprenticeships. This can build a skilled workforce, foster loyalty and promote long-term growth.

Focus on retention. Retaining employees is just as important as hiring them. Regularly check in with staff to understand their needs and concerns. Recognize achievements, offer career development opportunities and create a supportive work environment to keep morale high and turnover low.

Leverage local networks. Tap into your community to find potential hires. Attend job fairs, partner with local workforce development agencies and engage with community organizations. These connections can help you reach candidates who are already invested in your area and may be more likely to stay long-term.

Use social media and niche job boards. Promote job openings on platforms like LinkedIn, Indeed and industry-specific job boards to reach target audiences. Share employee testimonials, behind-the-scenes content and company updates to represent your brand and attract candidates who align with your values and vision.

Hiring talent continues to be a challenge for many small businesses, but there are practical steps that can make a real difference. For more attraction and retention resources, contact us today.