The Medicare Prescription Drug, Improvement, and Modernization Act of 2003 (MMA) requires groups that currently provide prescription drug coverage to Medicare beneficiaries to disclose whether their coverage is creditable prescription drug coverage.
The deadline for the annual determination is October 15, 2025.
Beginning January 1, 2006, Medicare beneficiaries gained access to subsidized prescription drug coverage through the newly established Medicare Part D program.
This mandate applies to all organizations offering such coverage, whether primary or secondary to Medicare, and ensures that beneficiaries are informed about how their existing plan compares to the standard Medicare Part D benefit.
Please review the Centers for Medicare & Medicaid Services (CMS) page on creditable coverage guidance to learn more.
Blue Cross NC mails group analysis notices around October 1 to all groups in the small group (1–50) market.
Blue Cross NC shares group analysis notices annually, around October 1, with all groups (including groups of 51+) along with group account management staff, employers (via Employer News on our Employer Services portal), and agents (via Agent News on our Agent Services portal).
Employer groups must communicate their creditable or non-creditable status to their members.
Beneficiaries who currently receive prescription drug coverage through an employer, union, or other source may opt to retain their existing plan.
If the existing coverage is deemed creditable – meaning it is at least equivalent in value to the Medicare Part D benefit – individuals may:
Continue receiving their current level of care.
Avoid late enrollment penalties should they decide to enroll in Medicare Part D in the future.
This provision ensures that beneficiaries with high-quality existing coverage are not disadvantaged and can make informed decisions about their prescription drug benefits.
Beneficiaries are encouraged to enroll during the initial open enrollment period to avoid late enrollment penalties.
Individuals who delay enrollment beyond their first eligible period may be subject to higher premiums if they choose to enroll at a later date.
There are some actions Medicare beneficiaries should take to ensure they have the best available plan and benefits at the lowest cost.
Review their drug coverage to determine if it qualifies as creditable coverage.
Compare available Medicare Part D plans to find one that meets their needs.
Enroll early to maximize benefits and avoid unnecessary costs.
Employers must determine and attest whether their group’s plan is creditable. (Employers should consult legal counsel regarding their obligation under MMA.)
Sending creditable / non-creditable coverage notices to their Part D-eligible members.
For a sample of the group creditable coverage letter and appendix for 2025 and 2026, you can contact your Blue Cross NC representative reach out to our employer services team.
Blue Cross and Blue Shield of North Carolina does not discriminate on the basis of race, color, national origin, sex, age or disability in its health programs and activities. Learn more about our non-discrimination policy and no-cost services available to you.
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