The Inflation Reduction Act (IRA) of 2022 has brought significant changes to Medicare Part D plans, which will affect the creditable coverage status of employer-sponsored prescription drug coverage for 2026. As a result, this may make it harder for certain plans to qualify as creditable coverage. To navigate these changes and ensure compliance, employers must proactively review their health plans’ prescription drug coverage status.
The checklist below is designed to help employers understand the implications of the new creditable coverage methodologies, assess their current plan’s creditable coverage status, and identify necessary adjustments to comply with federal requirements and support their Part D-eligible participants.
There are five steps to complete in this checklist:
- Analyze Part D Changes and Impact on Creditable Coverage
- Review the Final CY 2026 Part D Redesign Program Instructions from CMS
- Determine Plan’s Creditable Coverage Status: Employers should confirm the creditable status of their prescription drug plans as soon as possible to prepare to send the appropriate disclosure notices.
- Using the Revised Simplified Determination Method
- Using the Simplified Determination Method
- Using an Actuarial Determination
- Evaluate Each Benefit Option and Adjust Plan Design if Needed
- Applying the Creditable Coverage Test
- Prepare and Distribute Required Disclosures
- Disclosure Deadlines
- Document and Monitor Compliance
- Ongoing Regulatory Developments
Employers can use this checklist as a guide when reviewing your company’s compliance with Medicare Part D’s disclosure requirements for 2026. For assistance, contact Parrott Benefit Group.
This checklist is merely a guideline. It is neither meant to be exhaustive nor meant to be construed as legal advice. It does not address all potential compliance issues with federal, state or local standards. Consult your licensed representative at Parrott Benefit Group or legal counsel to address possible compliance requirements. © 2025 Zywave, Inc. All rights reserved.
