Lexology September 6, 2024
Venable LLP

The Inflation Reduction Act of 2022 made significant design changes to Medicare Part D effective January 1, 2025. The changes will cause an increase in the actuarial value of Medicare Part D coverage, which will impact whether a group health plan’s prescription drug coverage qualifies as creditable coverage. Plan sponsors should consult with their carrier or third-party administrator to determine whether their prescription drug coverage will require any enhancements to qualify as creditable coverage in 2025.

Background

Group health plans that provide prescription drug coverage to Medicare-eligible individuals must determine whether the coverage is “creditable.” Prescription drug coverage is “creditable” if the actuarial value of the coverage equals or exceeds the actuarial value of standard Medicare Part D prescription drug...

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