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.
This checklist 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.
1. Analyze Part D Changes and Impact on Creditable Coverage
2. 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.
3. Evaluate Each Benefit Option and Adjust Plan Design if Needed
4. Prepare and Distribute Required Disclosures
Use this checklist as a guide when reviewing your company’s compliance with Medicare Part D’s disclosure requirements for 2026. For assistance, contact Hodge, Hart & Schleifer.
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 Hodge, Hart & Schleifer or legal counsel to address possible compliance requirements. © 2025 Zywave, Inc. All rights reserved.