Does the Creditable Coverage determination have to be made by an Actuary?

By creditable coverage for a health plan, I assume you are talking about the HIPAA special enrollment rights against pre-existing condition elimination periods, and prior group coverage that must be taken into account if the gap is not more than 63 days. This would not require an actuary to determine.

I meant the annual Part D creditable coverage requirement. In addition to my initial question regarding an actuary, I am also wondering whether or not charges to provide this service by an actuarial firm are payable from a VEBA. Thanks.