This is a very interesting discussion. We had a situation last year during the OEP. The man showed up with Original Medicare, and VA Drug coverage, with no Part-D. He needed Medical and Part-D help, so we put him in a MAPD.
Even though he had Creditable Coverage through the VA, he was not allowed to add a Part-D Drug Plan. The rule is you cannot add or subtract a Part-D during the OEP.
We didn't like it, he didn't like it, but that was the way it was.
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Just because VA is creditable, does not mean it IS a Part D Medicare plan.... it ISN'T. The "like to like" comparison means a "Part D to Part D" plan. An MAPD is "like" a Stand Alone PDP in serving prescription coverage. Group insurance with Rx coverage may be creditable, but it is not "like" a PDP either.