Why aren't Medicare Part D creditable coverage notices required with an ICHRA?

Answer:

Medicare Part D creditable coverage notices are required when an employer sponsors a group health plan that includes prescription drug coverage.

An ICHRA does NOT provide group health or prescription drug coverage. Instead, it reimburses employees for eligible individual health insurance premiums. Because the prescription drug coverage is provided through the employee's individual health plan or Medicare—not the employer's ICHRA—the employer is not required to determine whether the coverage is creditable or provide Medicare Part D creditable coverage notices.

In short, because an ICHRA is a reimbursement arrangement rather than a group health plan with prescription drug benefits, the Medicare Part D creditable coverage reporting requirements do not apply.