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CMS Excludes Account-Based Plans from Medicare Part D Notices
Nixon Peabody LLP 
[Guidance Overview] Apr. 14, 2026 "The final rule codifies that account-based medical plans, specifically HRAs and ICHRAs, are no longer required to determine, document, or disclose their creditable coverage status to Part D-eligible individuals. CMS concluded that the fundamental design of account-based arrangements -- which provide tax-free reimbursements for medical expenses and individual policy premiums rather than comprehensive prescription drug benefits -- makes actuarial comparisons to the Medicare standard drug benefit inapplicable." MORE >> |
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