Creditable and Non-Creditable Coverage

Under regulations issued by the Centers for Medicare & Medicaid Services (CMS), Medicare Part D-eligible individuals must be notified whether their current coverage is "creditable prescription drug coverage" each year. The following are definitions of creditable and non-creditable coverage:

• Creditable coverage: A health plan's prescription drug coverage is creditable when the amount the plan expects to pay for prescription drugs for individuals covered by the plan in the coming year is, on average, the same or more than what standard Medicare prescription drug coverage would be expected to pay.
• Non-creditable coverage: A health plan's prescription drug coverage is non-creditable when the amount the plan expects to pay for prescription drugs for individuals covered by the plan in the coming year is, on average, less than that which standard Medicare prescription drug coverage would be expected to pay.

Employers must notify Medicare-eligible members whether their current plan is or is not creditable prescription drug coverage by October 15. Members in Blue Shield plans that have been determined as creditable do not need to do anything if they're satisfied with the drug coverage they have through these plans.

Members in Blue Shield plans that have been determined to have non-creditable coverage may do one of the following:

1. Do nothing and keep their current coverage. If they choose this option, they are not purchasing a Medicare Prescription Drug Plan (PDP) and may incur further late enrollment penalties if they choose to purchase a Medicare PDP in the future. There are no forms to fill out for this choice.
2. Purchase a Medicare Prescription Drug Plan during the next Annual Election Period. The late enrollment penalty will apply because the member's current plan is not creditable, and the employee did not choose to enroll in a Medicare PDP when they first became eligible. Within 63 days of enrolling in a Medicare PDP, employees must have the prescription drug coverage removed from their current plan per federal law.

The list below denotes which Blue Shield of California plans offer creditable prescription drug coverage and which do not. Effective January 1, 2023.

Individuals and Family Plans

Medicare Supplement

Small Business Plans

Midsize and Large Group

**All Custom plans with a combined Rx/Medical deductible and out-of-pocket maximum must be certified as either Creditable or Non-Creditable individually. Please contact your Blue Shield account representative for assistance with individual plan certification.

Web Resources - Medicare Part D

To learn more about Medicare Part D and how it can affect your Medicare-eligible retirees, please visit:

• Centers for Medicare & Medicaid Services Your Guide to Medicare Prescription Drug Coverage
• Retiree Drug Subsidy Program (RDS)

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Page last updated: 10/01/2022

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