Starting in 2027, plan sponsors will no longer be permitted to use the original simplified determination method to determine whether their coverage is creditable. Only the revised simplified determination method or an actuarial determination will remain available. For 2026 only, plan sponsors may still choose between the original and revised simplified methods (or an actuarial determination) but should begin preparing now for the 2027 transition. Note that employers applying for the retiree drug subsidy are not eligible to use either simplified method and must instead use an actuarial determination.

The chart below compares the original and revised simplified determination methods, including the criteria that plans must meet under each.