members covered in the individual and small group health insurance plan marketplace. That data was then calibrated to drug costs and utilization aligned with Medicare-eligible members. Methodology : The actuarial equivalence of plan offerings tested and the Standard Medicare Part D plan were evaluated using actuarial value (AV). AV is a measure of the percentage of total drug costs that the plan is expected to cover for a typical enrollee. The AV calculation considers the plan's cost sharing parameters, such as copays, deductibles, coinsurances, and OOP maximums. The AV of the plan sponsors’ offerings was compared to the AV of the standard Medicare Part D plan to determine whether the plan’s offerings were at least as “rich” as the Standard Medicare Part D requirement (>72%). As shown in the opening comments, all plans were found to provide drug coverage that exceeded the Standard Medicare Part D offering. Key Assumptions : Since the plans offered by the plan sponsor appear to be comprehensive major medical plans, and not minimum essential coverage plans or “skinny MEC” plans, it is assumed that the plans’ formularies include drug classes covering all disease states and a minimum of two chemically distinct drugs in each class. It was further assumed that plan sponsor cover drugs in each of the six protected drug classes: immunosuppressants, antidepressants, antipsychotics, anticonvulsants, antiretrovirals, and antineoplastics. If these assumptions are not true, it would invalidate the plans meeting the threshold for creditability. Additionally, CMS has been clear about the applicability of manufacturer discounts provided to Medicare recipients in the Standard Part D plan, and the impact that has on Part D creditability testing. Said another way, actuaries make assumptions about how manufacturer discounts offered to Medicare beneficiaries count as part of the richness of the Standard Part D plan. In accordance with the Part D guidance, Blue Raven Actuarial believes that the manufacturer discounts on Part D count toward the Part D creditability testing. Cautions and Limitations : This report and these results carry several cautions and limitations. Among the most important is that this analysis is not generalizable to other future health plan offerings. In other words, one should not assume that other plans with benefit components similar to the ones that were tested will affirmatively be creditable compared to the Standard Medicare Part D plans. Each plan should be reevaluated each year to determine creditability. There are other factors to bear in mind as well: Claims : The data used for this analysis is and was intended to provide a normative data set for use in calculations such as these. As claims experience emerges in the future, it would be prudent to use that data when refreshing this analysis, both to verify that the plans’ claims are being administered and adjudicated as intended, and to use the best and most relevant possible data to form conclusions about their drug plans’ creditability. Volatility : Volatility and fluctuations in claims data occur for reasons that are out of the control of Blue Raven Actuarial and the plan sponsor. Some of these reasons include, but are not limited to, 2 9 BLUE RAVEN actuarial info@blueravenactuarial.com