Article
Final Rule Exempts ICHRAs And Other Account-Based Plans From Medicare Part D-Creditable Coverage Notice
The Department of Health and Human Services has issued a final rule that eliminates the Medicare Part D creditable coverage notice requirement for account-based group health plans, including ICHRAs, HRAs, FSAs, and HSAs. This regulatory change addresses longstanding administrative burdens and confusion caused by dual messaging requirements, marking a significant shift in how these benefit arrangements interact with Medicare Part D disclosure obligations.
Foley & Lardner LLP



