Final Rule Exempts ICHRAs and Other Account-Based Plans from Medicare Part D-Creditable Coverage Notice

On April 6, 2026, the Department of Health and Human Services (HHS) published a final rule formally excluding account-based group health plans from the requirement to provide a Medicare Part D-creditable coverage notice to Part D-eligible individuals. This exclusion applies to individual coverage health reimbursement arrangements (ICHRAs), traditional health reimbursement arrangements (HRAs), health care flexible spending accounts (FSAs), health savings accounts (HSAs), and other account-based... By: Foley & Lardner LLP