Medicare Part D Creditable Coverage Attestation

Objective

Per the Medicare Modernization Act, entities that provide policies with prescription drug coverage must notify Medicare-eligible individuals whether their prescription drug coverage is creditable. A leading U.S. educational institution engaged Graeme Group to determine whether its employer-sponsored prescription drug plan met the Medicare Part D creditable coverage standard, as required under CMS regulations.

Scope of Work

Graeme Group was tasked with performing an actuarial equivalence analysis for the institution’s medical plans – focusing on the prescription drug component – and producing a certified attestation report.

Services Provided

Plan Design Review: Reviewed the prescription benefit structure including deductibles, copayments, out-of-pocket maximums, and dispensing limits for both retail and mail-order channels.

Actuarial Testing & Methodology: Conducted a gross value comparison against 2025 Medicare Part D standard coverage. Graeme Group normative claim data were used to reflect credible, population-based utilization estimates. Testing included derivation of adjusted plan expense values, benchmarking against Medicare thresholds, and evaluation under multiple pharmacy trend variances.

Regulatory Attestation: Prepared and delivered a formal certification confirming that the prescription drug program is creditable. All work was conducted in accordance with public practice as promulgated by the American Academy of Actuaries, the Actuarial Standards Board, industry best practices, and prevailing CMS guidance.

Key Metrics

The adjusted expense value for the employer plan exceeded the Medicare standard by over 19%, demonstrating sufficient evidence for passing the creditable coverage attestation.

Deliverables & Turnaround Time

Graeme Group provided the results within 48 hours after receiving the requested data:

• A formal attestation report indicating pass/fail status
• Documentation of data sources, methodology, and plan design
• Sensitivity analyses to support regulatory audit readiness
• Executive summary for use in compliance filings and employee communication
• Sign-off by a Fellow of the Society of Actuaries, Member of the American Academy of Actuaries, and Fellow of the Conference of Consulting Actuaries

Outcome

• Compliance: Delivered formal actuarial certification confirming creditable coverage status, enabling compliance with CMS disclosure requirements. Mitigated exposure to Medicare Part D late enrollment penalties for employees.
• Audit-Ready Documentation: Provided detailed documentation of methodology and results.
• Assurance: Report signed by a senior credentialed actuary, ensuring credibility.

In summary, Graeme Group performed a time-sensitive actuarial analysis to determine the creditability of the client’s employer-sponsored Medicare Part D plan. Leveraging normative claims data and in alignment with CMS and Actuarial Standards Board requirements, the team conducted a rigorous actuarial equivalence test and confirmed its creditable coverage status. Within 48 hours of receiving the required data, Graeme Group delivered a formal attestation report signed by a credentialed actuary and supporting documentation in order to support employee disclosure and compliance needs.