Defining Creditable Coverage Part D

[yorkriver1]

Ok, here’s how this is going to work in real life.

1. If you’ve got these people (past their IEP but get checked in on), get in front of them before Labor Day. If they are not contributing to an HSA, recommend enrollment in Part A ONLY.

2. If you work with Financial Planners (or want to), same answer. My FPs are creating lists now for an 8/2 email, zoom calls are scheduled by planner.

3. By 10/16, they should know if their coverage is creditable or not. General rule is that fully insured groups “should” be creditable (including $9450 deductible plans with no copays) and self funded plans are a crapshoot.

4. If they already have a Part A number, your life is so much easier. Whether they go all in with B or just Part D.

5. Dec 7 DOES NOT APPLY. They have until 12/31 for 1/1 and until 3/2 to enroll. (It’s 60 days and this isn’t a leap year.)

6. Everything comes into the mix. IRMAA. Cost of Employer coverage. Cost of Part D. LEP for 2025.

Thank you and please don’t forget the hat when it’s passed

Well thought out process. I have both of these things, prospects over 65 in the wings still working and CFP's referring, so for this and other situations, the steps you laid out are gold. Thanks!
I do have to confirm if employer group plans with plan years not set up for calendar year would still need to know if an employer group plan not renewing into 2025 coverage until after 1/1/25 would have a sort of backdated yes/no on creditable coverage as of 1/1/25 in the existing group plan year rather than as of the 2025 plan renewal date that could be any month beyond 1/1/25 from 2/1/25 to 12/1/25 renewal dates. Or was that addressed, and I missed the detail.

 

[LostDollar]

Well thought out process. I have both of these things, prospects over 65 in the wings still working and CFP's referring, so for this and other situations, the steps you laid out are gold. Thanks!
I do have to confirm if employer group plans with plan years not set up for calendar year would still need to know if an employer group plan not renewing into 2025 coverage until after 1/1/25 would have a sort of backdated yes/no on creditable coverage as of 1/1/25 in the existing group plan year rather than as of the 2025 plan renewal date that could be any month beyond 1/1/25 from 2/1/25 to 12/1/25 renewal dates. Or was that addressed, and I missed the detail.

(Caveat, not an agent)

This is a section from the article @somarco cited::

(Bolding in second paragraph is mine)
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" Determination Methodology Changes​

" Group health plans have two ways to determine if they provide creditable drug coverage: an actuarial determination methodology and a simplified determination methodology. Group health plans not applying for the retiree drug subsidy tend to use the latter since it’s less expensive and less complicated.


" Draft guidance for the Part D redesign suggested that plans would no longer be able to use the simplified determination to calculate the value of their plans; however, CMS is continuing to allow the use of both methods for CY2025 to mitigate the impact on group health plans.


" CMS is evaluating what Medicare Part D creditable coverage determination methods to allow for CY2026 and beyond. "

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Does this address the technical issues of the question asked?

 

[kgmom219]

Well thought out process. I have both of these things, prospects over 65 in the wings still working and CFP's referring, so for this and other situations, the steps you laid out are gold. Thanks!
I do have to confirm if employer group plans with plan years not set up for calendar year would still need to know if an employer group plan not renewing into 2025 coverage until after 1/1/25 would have a sort of backdated yes/no on creditable coverage as of 1/1/25 in the existing group plan year rather than as of the 2025 plan renewal date that could be any month beyond 1/1/25 from 2/1/25 to 12/1/25 renewal dates. Or was that addressed, and I missed the detail.

This is where it gets even screwier.

The group renewal date doesn’t really apply.

The letters have to go out by 10/15 for the upcoming calendar year.

So if a 7/1 group is creditable from 1/1/25 to 6/30/25, it’s creditable for 2025.

I think. Smarter than me people say that’s how it works now and should continue but I can’t find it in writing anywhere

 

[LostDollar]

(Caveat, not an agent)

This is a section from the article @somarco cited::

(Bolding in second paragraph is mine)
------------------------------------------------------------------

" Determination Methodology Changes​

" Group health plans have two ways to determine if they provide creditable drug coverage: an actuarial determination methodology and a simplified determination methodology. Group health plans not applying for the retiree drug subsidy tend to use the latter since it’s less expensive and less complicated.


" Draft guidance for the Part D redesign suggested that plans would no longer be able to use the simplified determination to calculate the value of their plans; however, CMS is continuing to allow the use of both methods for CY2025 to mitigate the impact on group health plans.


" CMS is evaluating what Medicare Part D creditable coverage determination methods to allow for CY2026 and beyond. "

-------------------------------------------------------------------------

Does this address the technical issues of the question asked?

This is where it gets even screwier.

The group renewal date doesn’t really apply.

The letters have to go out by 10/15 for the upcoming calendar year.

So if a 7/1 group is creditable from 1/1/25 to 6/30/25, it’s creditable for 2025.

I think. Smarter than me people say that’s how it works now and should continue but I can’t find it in writing anywhere

Caveat, I am not an agent
and I don't understand all the complexities of Part D.

However, re writing:

If the information I cited above from the Ritter link somarco posted is true,

Could one just say that plans that were creditable in 2024 would most likely be creditable in 2025, just because the "old rule set" that was used in 2024 could also be used in 2025?

 

[yorkriver1]

This is where it gets even screwier.

The group renewal date doesn’t really apply.

The letters have to go out by 10/15 for the upcoming calendar year.

So if a 7/1 group is creditable from 1/1/25 to 6/30/25, it’s creditable for 2025.

I think. Smarter than me people say that’s how it works now and should continue but I can’t find it in writing anywhere

Thanks for that clarification.
There was a trainer at one time with the tagline: Insurance is fun!
Will run this by the VP of compliance at my group upline. The law firm they use has a government compliance department. Not that you are lacking in great information. Just like to know how the people that are officially advising me/my clients are interpreting things. We can all learn from each other.

 

[kgmom219]

Would love to hear their feedback!!!

I have no problem with being wrong-if you can prove it to me in writing