Medicare Part D Creditable Coverage

mag11500

I recently took over handling benefits for our church. We use an outside insurance broker for our health care, but I can't always get the answers I need from an HR standpoint.  We have 2 active full time employees over the age of 65 who are on our health care. I recently received a post card from our carrier about Part D Creditable Coverage notice by November 15.  I have read posts on this and went on CMS's website to understand the requirements for giving notice and have determined that our prescription drug plan is creditable coverage and have a model notice to fill in the blanks to give to these two employees.  However, I can't figure out if we determine whether or not an employee can continue with coverage if they sign up for Part D or if we have the choice to say their coverage will end if they choose Medicare.  (Which will force them to go on Part B as well if they want medical.)  Do I have legal requirements to allow them to have both while actively employed?

Also, are we required to go onto CMS's website to complete the "Disclosure to CMS" form to provide our creditable coverage status?   No one in the office knows if we've ever done this in the past.