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HHS Proposed Rule Eliminates Medicare Part D Notice for ICHRAs
Foley & Lardner LLP 
[Guidance Overview] Dec. 17, 2025 "[HHS has] published a proposed rule ... that would carve out account-based group health plans from the requirement to provide a Medicare Part D-creditable coverage notice to Part D-eligible individuals. This exclusion would be welcome relief for account-based plan service providers and plan sponsors who offer an individual coverage health reimbursement arrangement (ICHRA) or another type of account-based group health plan, such as a health care flexible spending account (FSA), health savings account (HSA), or traditional health reimbursement arrangement (HRA)." MORE >> |
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