Multicolored wheel divided into 7 equal sections Recruitment, Training and Development, Benifits and Compensation, Communicating, Employee Relations, Recordkeeping, and Health safety and security with Legal compliance written on the outer edge and company strategy in the center benefits and compensation is emphasized

Medicare Part D Creditable Coverage Disclosure Due to CMS by March 1st


I just heard that I need to report my health plan “credibility” with CMS and my employees.  What in the world is this and what is it I need to do?


It’s time again for many employers to disclose Medicare Part D Creditable Coverage status to the Centers for Medicare & Medicaid Services (CMS). As a reminder, there are two disclosures required annually for certain employers related to Medicare Part D. Employers with plans providing prescription drug coverage to individuals that are eligible for Medicare Part D must disclose whether their drug benefit is equal to or better than (also known as “creditable”) the Part D program to (1) individuals eligible for Medicare Part D and (2) to CMS. The disclosure to CMS is due by March 1st for calendar-year plans.

At a minimum, disclosure to CMS must be made within:

  • 60 days after the beginning of the plan year;
  • 30 days after the termination of the prescription drug coverage; and
  • 30 days after any change in the creditable coverage status of the prescription drug plan

Employers must submit the disclosure online via form CMS-10198, providing the following information:

  • Name of Entity
  • Federal Tax Identification Number (EIN)
  • Entity geographical information
  • Phone number of entity
  • Type of coverage
  • Creditable coverage status
  • Identify “authorized individual” of the entity

As mentioned, any employer offering prescription drug plan is required to disclose creditable coverage status.  However, there are limited exceptions including (1) employers who contract directly with Medicare as a Part D plan (or contract with a Part D plan to provide qualified retiree prescription drug coverage) are exempt from the disclosure requirement for that plan year; (2) employers not offering prescription benefits to any Medicare D eligible individuals on the beginning date of the plan year are not required to complete a disclosure to CMS form for that plan year; (3) employers and unions that have applied and been approved for the Retiree Drug Subsidy (RDS) are exempt from filing the form. The exemption applies only to the covered members and plan options for which the employer is claiming the RDS. The plan sponsor’s RDS application will serve as disclosure to CMS.

For background, Medicare eligible individuals may pay higher premiums for Part D coverage if they fail to enroll in Medicare Part D during their initial enrollment period (beginning 3 months prior to 65th birthday and ending three months after 65th birthday) and have a lapse of creditable prescription drug coverage for more than 63 days.  This disclosure assists CMS with administering penalties as applicable to late enrollees. Further guidance and instructions for disclosure is found at CMS Creditable Coverage. Please contact your HORAN account representative with additional questions.

Thank you to HORAN for providing the content for our Question of the Week. HORAN serves as a trusted advisor on employee benefits, wealth management and life and disability insurance. To learn more about HORAN, please contact HORAN for additional information.

strategic HR inc. is ready to assist you with any of your challenging situations around Benefits and Compensation. We offer assistance with everything from job descriptions to policy development to help address your difficult issues that impact employee compensation or benefits. Please visit our Benefits and Compensation page for more information on how we can assist you.

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Key Components of an Onboarding Plan


What are the key components of a good onboarding plan?


With record low unemployment rates, anyone who is responsible for hiring new talent understands how difficult it is to find the right person with the right skillset to meet your needs. Many companies have had to review and dramatically modify their recruiting approach to create a candidate experience that attracts the best talent. Once you find the right candidate, you certainly want to do all that you can to keep them! Having a well-designed and well-executed onboarding plan will allow you to build upon a great candidate experience, and it is a key step to retaining your new employees.

A great way to determine the important components of an onboarding plan is to ask the target audience – the new employees. According to BambooHR’s employee onboarding survey, here are the top four things that employees value the most in their first week:

  1. On-the-job training (76 percent)
  2. Review of the company’s policies, such as dress code, time-off policy, etc. (73 percent)
  3. Review of administrative procedures, such as a touring the facility and setting up their work station (59 percent)
  4. Assignment of an employee “buddy” or mentor (56 percent)

 Onboarding – What To Do Before The First Day
Your onboarding efforts should begin from the moment that an employee accepts an offer. Here are a few things you should address before your new employee’s first day:

  • Good communication is key!
    Encourage your new hire to ask questions- even before they start. By addressing employee questions before their first day, you can help to ease their concerns and make for a smooth transition into your company. Also, be sure to answer their questions promptly.
  • Introduce the employee to staff BEFORE they start.
    Ask the new employee to provide some information about themselves that can be shared with the current staff before their arrival. This makes it easy for your team members to make connections with your new employee right from the beginning.
  • Prepare their work station.
    Although the work area may look and feel different depending on the nature of the employee’s role, it should be clean and have all of the equipment they need (i.e., desk, chair, phone, computer, printer, etc.) in a state that’s ready to use. Remember that small personal touches (i.e., welcome sign at their work station, welcome card from their manager/team, desk plant or small gift, etc.) can go a long way to helping your new employee to feel welcomed and valued.
  • Have technology and related resources ready.
    Ensure that their computer is ready and has all the necessary software and email installed so they can be up and running on their first day.
  • Assign a Mentor/Buddy.
    Choose someone who will be a positive and helpful resource who knows the company and the nature of the new hire’s job well so they can effectively answer questions.
  • Create an on-site employee onboarding plan. 
    It’s helpful to develop a checklist to ensure that you include all of the necessary paperwork, company information, and training that the new hire should receive. Develop a list of actions they should take within the first week and at 30-60-90 days so they can understand and meet your expectations. Be sure to have scheduled check-ins on these items so you can help your new employee to stay on track and make adjustments as necessary.
  • Train your team to be good hosts.
    Beyond providing the “nuts and bolts” in your onboarding, remember that your new employee is probably nervous and looking to feel accepted and connected to your company. By following the spirit of being a good host (i.e., encouraging staff to greet the new employee, providing opportunities to make connections with their team members in their early days, allowing ample time for their questions and feedback, etc.), it can make the beginning days/weeks much more comfortable and enjoyable leaving a positive impression on your new employee.

By taking the time to develop a solid onboarding process, you provide a great foundation on which your new employees can build their career with your company. By making their first days/weeks/months a positive experience, you will also dramatically increase their productivity, engagement, satisfaction, and retention with your company.

Training and Development of your employees is a key factor in remaining competitive. Not only does it keep you up-to-speed technologically with your competitors, but it also gives you the edge when recruiting or retaining employees. strategic HR inc. provides a variety of resources to offer you the best in training programs to keep you on the leading edge. Visit our Training and Development page to learn how we can assist you with your training and development.

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Setting Guidelines for Celebrating Halloween in the Workplace


With Halloween right around the corner, we’d like to allow our employees to wear costumes to celebrate Halloween in the workplace but we are worried it could get out of hand. Do we need to have some kind of guidelines?


As you may have seen, some schools have migrated away from celebrating Halloween to having a Fall Harvest celebration.  For some, Halloween represents the celebration of Satan. To others, Halloween is just a fun holiday where we dress up and “trick or treat”.  The real meaning behind Halloween was to wear costumes to ward off ghosts and over time became All Hallows Eve or the day before All Saints Day in honor of the saints.

All that said, the festivities of Halloween can be a fun team and morale boosting event in your office – dressing up, decorating your work station, or sharing treats.  While it still may only be one day, ensuring you set some guidelines for your employees to know what is okay to wear in the workplace on Halloween can help minimize problems.

Awareness: Not everyone may be comfortable in participating in the festivities and some may even find the holiday offensive.  You won’t want to make participation mandatory as it could actually create morale issues. Keep it fun and voluntary.

Culture: The culture of your organization will also impact how you handle the festivities.  How will your customers (i.e. corporate, kids, techie) respond to costumes when they interact with you for the day?

Families: Is this a holiday that would allow you to include your employees’ family? Perhaps it is a chance for the kids to come to work and trick or treat the different workstations or departments. Or maybe you have an evening bonfire with hayrides through a pumpkin patch.

Harassment: Be sure your guidelines to dress up for Halloween at the office include reminding employees of the company harassment policy.  All costumes need to be G rated to minimize hostile or harassment perceptions. Consider sharing with employees what they shouldn’t do (See 5 Rules for Celebrating Halloween at Work). As mentioned in a SHRM article, “according to a national labor and employment law attorney, who says employers could be held liable for problems resulting from Halloween garb that is sexually provocative, carries a political or social message or is just plain inappropriate for workers interacting with colleagues and clients.” Just because it is a holiday does not excuse employees from doing anything in violation of the company harassment policy.

A few tips for celebrating Halloween in the workplace according to this SHRM article include:

  • Communicating costume guidelines in advance including what not to wear
  • Don’t overact, but be sensitive
  • Be sensitive to subtleties
  • Reflect on last Halloween and feedback the company received from employees and customers
  • Consider alternative ways to celebrate
  • Be prepared to discipline if necessary

If you’d like to drive some fun into the work environment, there are many no-cost/low cost ideas to celebrating Halloween in the workplace:

  1. Office Space Decorating – Employees can bring in their unused decorations from home to keep the cost down. Make it a team event by having everyone help decorate the office and then decorating their individual workspace.
  2. Costume Theme – Create a costume theme for everyone to follow may help minimize the inappropriateness (i.e. Disney). Consider having employees donate $5 to wear a costume and donate the money to a local charity.
  3. Potluck lunch – Create a “boo-ffet” for the lunch. Make a sign-up sheet for employees to sign up for the main course, side dish, dessert, cups and napkins.
  4. Pumpkin Carving Contest – This can be a fun competition between departments and teams. Have a fun prize for the winner like a gift card to their favorite lunch place
  5. Collect Halloween candy and donate by sending care packages to the troops.

Did you know that allowing your employees to wear costumes for Halloween may even increase your employee engagement? According to an OC Tanner survey:

  • 73% of those who can dress up at work are highly motivated to contribute to the success of the organization they work for, compared to 58% of those who can’t come to work in costume.
  • 68% of those who can dress up are proud to tell others they work for their organization, compared to 58% of those who can’t.
  • 65% of those who can dress up would recommend their organization to a friend as a good place to work versus 49% of those who can’t.
  • 73% of those who can dress up fully support the values for which their organization stands, versus 58% of those who can’t.

Halloween can be a great excuse to have some fun with co-workers. You just need set some boundaries and be clear on what is crossing the line in celebrating Halloween in the workplace.

At strategic HR inc., we offer a variety of team building and team development programs targeted to help get teams back on track for success. Each program is customized to meet the team’s dynamics and needs. For more information on our Team Effectiveness Programs, click here.