OBJECTIVE To determine whether racial and ethnic minorities were less likely to meet the Medicare Part D eligibility criteria for medication therapy management (MTM) services compared with whites among the adult non-Medicare population, because some non-Medicare health plans have followed the Medicare example. DESIGN Cross-sectional observational study. SETTING United States, 2007-08. PATIENTS 16,691 white, 5,923 black, and 9,242 Hispanic adults (>17 years) among the non-Medicare population. INTERVENTION Analysis of the Medical Expenditure Panel Survey. MTM eligibility criteria used by Part D plans in 2008 and 2010-11 were examined. Main and sensitivity analyses were conducted to represent the entire range of the eligibility thresholds used by Part D plans. Analyses also were conducted among individuals with heart disease, diabetes, and hypertension. MAIN OUTCOME MEASURES Proportions and odds of patients meeting Part D MTM eligibility criteria. RESULTS According to the main analysis examining 2008 eligibility criteria, whites had a higher proportion of eligible individuals than did blacks (3.73% vs. 2.57%) and Hispanics (1.53%, P < 0.05 for both comparisons). According to survey-weighted logistic regression adjusting for patient characteristics, blacks and Hispanics had odds ratios for MTM eligibility of 0.60 (95% CI 0.46-0.79) and 0.54 (0.40-0.72), respectively, compared with whites. Sensitivity analyses, analyses examining 2010-11 eligibility criteria, and analyses among individuals with heart disease, diabetes, and hypertension produced similar findings. CONCLUSION Racial and ethnic minorities have lower odds for meeting Part D MTM eligibility criteria than whites among the adult non-Medicare population. MTM eligibility criteria need to be modified to address these disparities.