I have a question about the simplified determination of creditable coverage test that was set forth in the CMS creditable coverage guidance. Specifically, a prescription drug plan is deemed to be creditable if it "provides reasonable access to retail providers, and optionally, for mail order coverage," among other things.

Assuming a plan meets all the other requirements but doesn't provide mail order coverage, does this mean that the plan does not satisfy the simplified creditable coverage test? Alternatively, does a plan have to offer mail order coverage in order to meet the simplified creditable coverage test?

Thank you in advance for any thoughts.

Did you ever get a response to (or otherwise resolve) this question? We have a similar issue at the moment. Thanks.

Your quote uses the phrase "and optionally, mail order coverage.....". The word optionally would indicate that mail order coverage is not necessary.