Medicare Part D Creditable Coverage – 2027 Small Group Health Plans

Updated on: October 28, 2026 | By Word & Brown General Agency | California & Nevada

Beginning with plan years starting in 2027, new federal testing standards apply when determining whether employer-sponsored prescription drug coverage is considered creditable or non-creditable under Medicare Part D. These changes may cause some plans that were previously considered creditable to become non-creditable in 2027.

To help brokers and employers prepare, Word & Brown has surveyed our fully insured carrier partners to identify the Medicare Part D creditable coverage status of their 2027 Small Group plans in California and Nevada. The information below identifies Small Group plans determined to be non-creditable under the new 2027 standards. Some carriers are still finalizing their determinations, and we will update this resource as additional information becomes available.

What Small Group Employers Should Do at Their 2027 Renewal

When renewing or selecting Small Group coverage for a plan year beginning in 2027, employers should review the Medicare Part D creditable coverage status of their new plan, even if their existing coverage has historically been considered creditable.

Employers are required to notify Medicare-eligible individuals whether their prescription drug coverage is creditable or non-creditable. We recommend making this determination part of the annual renewal process and providing the appropriate Medicare Part D notice to affected individuals before their new coverage takes effect.

Employers must also provide an annual Medicare Part D notice before October 15 each year (no later than October 14) to Medicare-eligible employees and dependents, regardless of whether their coverage is creditable or non-creditable. If a plan's creditable coverage status changes, affected individuals must also be notified of that change.

For additional information about the new 2027 standards, disclosure requirements, and employer responsibilities, read our Medicare Part D Creditable Coverage Is Changing for 2027: What Brokers Need to Know column.

California Small Group Non-Creditable Plans

(Aetna)

ACA Plans

CA Bronze HMO $85/125 9400
CA Bronze HMO $85/125 9400 wINF
CA Bronze MC 100 7800 HSA M
CA Bronze MC 100 7800 HSA wINF
CA Bronze MC 50/50 9000
CA Bronze MC 50/50 9000 wINF
CA Bronze MC 60/50 6500
CA Bronze MC 60/50 6500 wINF
CA Bronze MC Savings Plus 100 7800 HSA M
CA Bronze MC Savings Plus 100 7800 HSA wINF
CA Bronze MC Savings Plus 50/50 9000
CA Bronze MC Savings Plus 50/50 9000 wINF

AFA Plans
View the list of plans that Aetna has determined may not be Medicare Creditable.

(Blue Shield of California)

Blue Shield Trio Bronze 60 HMO 7000/65 PCP + Child Dental Alt
Bronze Access+ HMO 7000/65 OffEx
Bronze Local Access+ HMO 7000/65 OffEx
Bronze Trio HMO 7000/65 OffEx
Silver Full PPO 2550/75 OffEx
Silver Tandem PPO 2550/75 OffEx
Silver Full PPO 1800/65 OffEx
Silver Tandem PPO 1800/65 OffEx
Silver Full PPO 2100/75 OffEx
Silver Tandem PPO 2100/75 OffEx
Bronze Full PPO 6500/70 OffEx
Bronze Tandem PPO 6500/70 OffEx
Bronze Full PPO 4500/65 OffEx
Bronze Tandem PPO 4500/65 OffEx
Bronze Full PPO 7500/65 OffEx
Bronze Tandem PPO 7500/65 OffEx
Bronze Full PPO 6250/65 OffEx
Bronze Tandem PPO 6250/65 OffEx
Blue Shield Bronze 60 PPO 5800/60 PCP + Child Dental
Blue Shield Bronze 60 PPO 5800/60 PCP + Child Dental
Silver Access+ HMO 2850/70 OffEx
Silver Local Access+ HMO 2850/70 OffEx
Silver Trio HMO 2850/70 OffEx
Silver Access+ HMO 2100/70 OffEx
Silver Local Access+ HMO 2100/70 OffEx
Silver Trio HMO 2100/70 OffEx
Bronze Full PPO 6850/55 OffEx
Bronze Tandem PPO 6850/55 OffEx
Blue Shield Silver 70 PPO 2500/60 PCP + Child Dental
Blue Shield Access+ Silver 70 HMO 2500/60 PCP + Child Dental
Blue Shield Trio Silver 70 HMO 2500/60 PCP + Child Dental
Gold Full PPO 1000/30 OffEx
Gold Tandem PPO 1000/30 OffEx
Gold Full PPO 750/35 OffEx
Gold Tandem PPO 750/35 OffEx
Gold Full PPO 500/30 OffEx
Gold Tandem PPO 500/30 OffEx
Gold Full PPO 0/35 OffEx
Gold Tandem PPO 0/35 OffEx

(CalCPA Health)

Bronze PPO 50/6500/3
Silver PPO HSA 4000 PPO
Bronze PPO HSA 5200 PPO
Bronze PPO HSA 6600 PPO

All of the PPO plans listed are also offered on the Select PPO network, except for the Coupe Health AHPs (“-C” suffix); the creditable/non-creditable determination is the same regardless of provider network.

Source/Links

2027 CalCPA Creditable Coverage

(Kaiser Permanente)