Part D Creditable Coverage 2025

kgmom219

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I just sent this out internally and thought I would share. Hope it helps!

Issue
  • People over 65 who are still working need to have creditable drug coverage or risk becoming late enrollees later, with a lifetime penalty. Every October, employers are required to notify their employees if the group coverage is creditable or not for Medicare Part D. Right now, 99.9% of group plans are creditable vs Part D and it’s a non-issue.
  • For 2025, no one seems to know the answer on what is creditable or not. I got with the actuary who did the TX ACA alignment and he said that “in general” fully insured plans will be creditable, but self-funded plans are a crapshoot. Assume that any employer over 100 employees is self-funded, but it really doesn’t matter. We need to know what the letter says in October. We can’t guess.
Game Plan
  • I’m getting in front of Financial Planners now with this potential issue. One, so we look smart and sound pretty. Two, I am NOT dealing with panic calls on October 15. No. No. No.
  • Financial Planners are identifying anyone over the age of 65, who is not on Medicare.
  • Financial Planners will be sending emails to their clients (copying me) the first week of August. We need another friggin tab on the spreadsheet.
    • Under 5 people? That’s individual meetings in August and that’s fine
    • A lot of people? We will be doing a Zoom meeting per planner.
  • If they are not enrolled in Part A AND not contributing to an HSA account, we are getting them enrolled in Part A prior to October 1.
  • If they need a Part D plan, its going to be an individual answer on what we do. And I can’t even guess on the answer until we get the Part D premiums for 2025. In September. Plus, most of these people will be IRMAA, so that’s in play as well. SUPER DUPER FUN!
  • Financial Planners are aware that if its not an easy answer, the client enrollment meetings will occur after Dec 7th and I will being telling the clients that as well. Technically, they have until March 1 to enroll, without a penalty.
 
FWIW in the 90's I tried to get health insurance carriers to define creditable coverage which allows the pre-ex clause to be waived. (This predates Obamacare).

Not a single one I talked with could give me a workable definition.

It was more like, "We can't define it but I will know it when I see it . . ."
 
FWIW in the 90's I tried to get health insurance carriers to define creditable coverage which allows the pre-ex clause to be waived. (This predates Obamacare).

Not a single one I talked with could give me a workable definition.

It was more like, "We can't define it but I will know it when I see it . . ."
That’s what they saying right now. But until the plans are finalized (self funded side) who knows
 
Has CMS ever checked to see if their coverage was credible? I imagine most just mark they had employer coverage from when they turned 65 until their Medicare Part B started and no one questions it.
 
With the new more generous Rx coverage I assume this is the deal with what's next for creditable coverage notices. So glad I saw this now. Thanks! There is a VP of compliance at the firm I work with for group coverage (large operation) who I will suggest to be in touch with the law firm that works on insurance and HR compliance consulting for them.
 
Reply from the compliance VP at my upline for group & ACA coverage:
Currently, we receive CC (creditable coverage) information for all plans within a calendar year, so the 1/1/25 change is not included for a 2024 plan year. Creditable HDHP (CC) plans covering preventive prescriptions before the deductible might be non-creditable (NC) as of 1/1/25
We are reaching out to our carrier/TPA partners on this to see what changes they will make to the CC and NC lists in advance of 1/1/25.
 

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