Creditable coverage reminder

Employers offering group health plans with prescription drug coverage to individuals who are also eligible for Medicare Part D must comply with certain disclosure requirements as outlined by the Centers for Medicare & Medicaid Services (CMS).

They must disclose, for example, if their prescription drug coverage is at least as good as the Medicare Part D coverage – or if their coverage is "creditable." These disclosures must be provided on an annual basis and at certain other designated times.

The annual federal Medicare Part D “Notice of Creditable or Non-Creditable Coverage” notice must be sent to employees by Oct. 15, 2026.

Here's how the process works:

1. Send the Medicare Part D Notice of Creditable or Non-Creditable Coverage to your employees and COBRA participants by Oct. 15, 2026 (if you need a list of COBRA participants, please let us know).
2. Make sure the notice is included in all new hire packets.
3. Complete and submit the Disclosure to CMS form electronically.

Download the following items:

• Memo: this document explains your tasks and how to determine if your plan is "creditable" or "non-creditable." The attached memo includes the 2027 "non-creditable" plans.
• Non-creditable coverage notice: if your plan is "non-creditable," you will send CMS Form 10182-NC.
• Creditable coverage notice: if your plan is "creditable," you will send CMS Form 10182-CC.
• Medicare coverage form: send this document with the creditable coverage notice. Only individuals that have Medicare coverage need to complete and return this form to ensure that we are correctly coordinating their health insurance benefits.

Important note: if you offer two plans and their creditability is different, you need to provide the appropriate notice to the plan selected by your employee.

This material is not considered legal advice. If you offer additional prescription drug benefits, please seek information from the appropriate carrier.

Annual Out-of-Area Verification Form

Sanford Health Plan (SHP) is sending members who reside outside the SHP service area a reminder about the annual Out-of-Area Residence Form, which is due by Dec. 2, 2026. College students and dependents with a permanent residence outside the SHP service area need to have this form on file to ensure access to Multiplan’s nationwide network. As a reminder, members enrolled in a Sanford TRUE plan are not eligible. Letters will be sent to affected members in mid-October. See an example form and letter. Once we receive the form, allow 14 business days for processing and will notify members of a decision by mail.

Small group TRUE 2027

For plan year 2027, Sanford TRUE eligibility for small employer groups will continue to be based on the employer’s location and where employees live. Businesses must be domiciled in an approved county to offer Sanford TRUE plans, and employees must live within an approved ZIP code to enroll. There are no changes to the approved county or ZIP code lists for 2027. Small group eligibility requirements differ from large group due to regulatory requirements, including rating regions and network access standards. Your account manager is available to help answer questions about eligibility and plan options.
 
Reminder: After open enrollment closes, employees generally cannot change their plan selection until the next open enrollment period unless they experience a Qualified Life Event that allows them to make a change.

Large group TRUE and PLUS 2027

Starting in 2027, eligibility for TRUE and PLUS plans will be based on your business location rather than where your employees live, making it easier to support today’s more geographically dispersed workforce while maintaining access to high-quality, cost-effective care. For more information about this change and what it means for you and your employees, review our employer FAQ and employee FAQ document. 

834 File submission reminders (for large groups)

• Submission window: Dec. 1–5, 2026
• Files submitted after this window may result in processing delays and possible member disruption.
• Please review event dates, effective dates, and all enrollment data carefully to avoid billing or coverage issues.

ID card redesign coming for commercial plans

Sanford Health Plan will begin issuing newly designed member ID cards for commercial plans effective Jan. 1, 2027. The updated format includes improvements designed to enhance member experience.

What is changing?

• Members’ primary network will be listed on the front of the card.
• The card design includes space for a future QR code, allowing members to quickly access plan information and resources. Additional digital enhancements will eventually include Apple wallet integration.
• Digital ID cards will be available for members in MyChart, helping create a more seamless and integrated member experience.
• ID cards will be issued at the individual member level, meaning all subscribers and dependents will receive a card displaying their own name.

What is not changing?

• Member benefits and coverage remain the same.
• Existing ID cards remain valid as long as the plan is active.

Who will receive a new card?

• Members with MultiPlan as their primary network AND who have addresses outside the service area will receive new ID cards during the 2027 open enrollment period.
• All other affected members will receive the updated card at routine touchpoints, such as policy or benefit changes and replacement card requests.

$5 Preventive drug resources

Eligible HDHP members will continue to have access to covered preventive medications at a $5 cost-share, just as they do today. Rather than using separate preventive drug lists or marketing materials, members will be directed to approved resources that provide the most current coverage information, including:

• The Sanford Health Plan Formulary
• Member-specific benefit documents available through the member portal

We encourage you to share this information with employees enrolled in eligible HDHP plans so they know where to find the most current information about their preventive drug benefits.

A new name for ICHRA: CHOICE Arrangements 

The federal government has introduced CHOICE Arrangements (Custom Health Option and Individual Care Expense) as the new name for Individual Coverage Health Reimbursement Arrangements (ICHRAs). While the name is changing, the benefit remains the same. CHOICE Arrangements continue to provide employers with a tax-advantaged way to help employees pay for individual health coverage. Our CHOICE partner, Thatch, offers additional information about the new terminology, what it means for employers and what to expect moving forward. Learn more here.

To improve our member experience, we will implement an in-house subrogation model for 2026/2027. Please find a sample member letter for your files. Subrogation is the process where research is completed to determine if another vendor is liable for a claim as a result of an accident (i.e., Workers Comp or auto insurance).
 
Bringing this function internally will provide greater oversight of the member experience, enable closer alignment with our service philosophy and enhance coordination across teams supporting claims and recovery activities.   

Small and large group support
Your Sanford Health Plan service team is here to support all of your group business needs. Please reach out directly to your assigned account executive (AE) or account manager (AM) with questions.