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Writer's pictureSarah Borders

Do employers need to change how they determine Medicare Part D creditable coverage status?

Updated: May 23



In today's video, we discuss the recent changes issued by CMS regarding Part D coverage and how it may affect employer-sponsored group health plans. Let's delve into the details of these changes and what they mean for both individuals and organizations.


Overview of CMS Fact Sheet on Part D Coverage


Under the recent CMS fact sheet, we learned that plans can now use a simplified determination to assess if their coverage meets the standards for Part D coverage. This determination is crucial as it helps individuals decide whether to opt for Part D coverage or remain on their employer's group health plan. Failure to provide accurate information on creditable coverage can impact the lifetime costs for individuals.


Changes Under the Inflation Reduction Act for Part D Coverage


Significant changes were introduced under the Inflation Reduction Act, affecting various aspects of Part D coverage. These changes include lower out-of-pocket maximums, revised coverage for vaccines and insulin, and alterations to how Part D covers specific drugs. Notably, there is now flexibility in negotiating the coverage of a list of ten drugs with Medicare and the federal government.


Impact on Employer-Sponsored Group Health Plans


The take-away here is for employers to evaluate how these changes in Part D coverage will impact their group health plans' creditable coverage status. While plans can still rely on simplified determinations, it is advisable to consult with actuaries or carriers to ensure the coverage remains creditable. Employers must consider these factors when renewing their plans as the changes come into effect for 2025, 2026, and beyond.


The evolving landscape of Part D coverage requires a thorough understanding of the recent changes for both individuals and employer-sponsored group health plans. By staying informed and seeking expert guidance, organizations can navigate these shifts effectively and provide their employees with the necessary information to make informed decisions regarding their healthcare coverage.

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