Kilpatrick

Carrier News

Group Health Plans – Determination of Medicare Part D Creditable Coverage Status

Employers are required to provide notices to Medicare-eligible individuals covered by their prescription drug plan about whether the plan is creditable coverage with Medicare Part D and are required to submit the plan’s creditable status to CMS annually using an online form. The employer—not the insurer or plan administrator—is responsible for determining whether the plan is creditable, providing the requisite notices to covered individuals, and completing the online disclosure to CMS form. A prescription drug plan is creditable if the coverage is as or more generous as a standard Medicare Part D benefit.

  • Member Notices – Employers must provide the notices to each Medicare-eligible individual each year before October 15, prior to his initial enrollment period (prior to joining the plan), and whenever the coverage terminates or its status changes (from creditable to not and vice versa). Employers should use the model notices published by CMS.
  • CMS Disclosure – Employers must provide a disclosure to CMS within 60 days after the beginning of each plan year and within 30 days after the termination of a plan or its change in creditable coverage status. Use the Disclosure to CMS Form.

Resources, Support, and Intelligence from Each Carrier

The vast majority of standard health plans provide creditable coverage. Generally, the only major medical plans with non-creditable drug coverage are high deductible health plans like HSA-compatible plans with out-of-pocket maximums near the statutory limits that do not provide a first-dollar drug benefit.

CarrierResources/SupportPlans Likely Not Creditable
BCBSProvides a determination guide (Sep 2020) to employers.B662CHC, B661ADT
CignaAccount manager assists upon request. Virtually plans they administer are creditable due to the pharmacy designs they offer.None of their 'packaged plans'. Possible, but unlikely, with certain custom designs.
Memorial HermannIdentifies plans each year. They say these plans are not creditable, but we think all of their plans are.Hybrid plans: 6350 HSA HMO, 5000 HSA HMO
Large Group plans: 6350 HSA PPO, 6550 HSA HMO, 5000 HSA HMO
National GeneralVariable
HumanaProvides grids for the drug plans offered in each segment and their creditable status on this resource page.LFP plans: On Hand Opt 1, EHDHP Opts 8 & 10
2020 Small Group plans: all Coins plans, HDHP Opts 7, 8, 10, & 11
2021 Small Group plans: all Efficiency plans, SaveHSA Opts 5 & 6
Large Group: EHDHP Opt 24
Scott & WhiteProvides notices to all employer groups the first week of Oct and publishes the notices in the employer and producer portals.Unsure.
UHCExplains the requirements on this resource page. Provides a small group plan lookup tool in Excel and a custom calculator tool for plans in other segments (bottom of page)None in small group. Unsure about large group.
UHC All SaversAll plans are creditable-
AetnaDetermines status of each plan after the effective date.Variable

For more information, visit https://www.cms.gov/CreditableCoverage/

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