What the 2026 CMS Rule Change Means for Employers

Starting in 2026, CMS is raising the bar for what qualifies as creditable prescription drug coverage under Medicare Part D. For employers and benefits advisors, this is a big deal, and waiting until Q4 to react could be risky.

What’s Changing?

CMS will increase the actuarial threshold for simplified creditable coverage determinations from 60% to 72%. That means your group drug plan must now cover at least 72% of expected prescription drug costs to be deemed creditable.

Why It Matters

Many plans that previously passed under the 60% standard may now fail under the 72% test. That puts both compliance and employee trust at risk, especially if proper notices aren’t sent.

What You Should Do:

• Review your 2026 drug plan design early

• Run a creditable coverage test using the new 72% methodology

• Send compliant notices to Medicare-eligible employees before October 15

With Creditable, you can test plans instantly and generate CMS-compliant determination letters with ease, no waiting on the carrier or TPA.