Medicare and Employer Coverage

Key Points

If you actively work for an employer with 20 or more employees and are covered under that employer’s insurance, you can likely delay Medicare past 65 without penalty.
Working for an employer with less than 20 employees does not count as having creditable coverage, so you will likely want to sign up for Medicare when you are first eligible to avoid penalties.
Retiree coverage, including COBRA, does not count as creditable coverage for Medicare.

If you are 65+ (or turning 65 soon) and will have both Medicare and Employer Coverage because you are still actively working, you will have a number of things to think through.

You likely have options to keep your employer insurance and Medicare will coordinate with that coverage. You’ll also want to compare the cost of that employer coverage against what it would cost you to roll over to Medicare as your primary insurance.

Doing your research will help you decide on which coverage option is most cost-effective. It can also help you avoid any Medicare late enrollment penalties wherever possible. Again, this info below is for beneficiaries age 65 or older. (Medicare coordination rules are different for people under age 65 on Medicare due to disability.)

Active Employer Coverage

Active employer coverage means you are still actively working, not retired. In this scenario, you have the right to remain on your employer’s group health insurance plan if you choose. Your Medicare benefits can coordinate with that coverage. HOW it coordinates depends on the size of your employer.

These same rules apply if your group health coverage is through your spouse’s employer.

Medicare and Employer Coverage – Large Companies 20+ Employees

Medicare is secondary if you are age 65 or older and your employer has more than 20 employees and you are still ACTIVELY working (not a retiree or on COBRA). This is called Medicare Secondary Payer. In this scenario, your group plan pays first, and then Medicare pays second. (People under 65 on Medicare, click here for different rules).

Most active employees with group coverage enroll in Part A because it is premium-free if you have worked at least ten years. Part A can coordinate to lower your costs if you have a hospital stay. For example, let’s say your employer health plan has a $3,000 deductible. The Medicare Part A hospital deductible is $1,600 in 2023. So if you have both your employer insurance and Part A, and you incur a bill for a hospital stay, you will only be out $1,600 for your inpatient hospital services. Medicare pays the rest of any Part A services.

It doesn’t necessarily work the same way with Part B, and Part B costs money (see next section), so that’s why most people choose Part A only when working for a large employer. One exception would be if you are contributing to an HSA and plan to continue doing so. If that’s the case, do not enroll in Part A. Read more on that below.

Medicare as Secondary Insurance Costs Money

Now Part B is not premium-free. You will pay a monthly premium for Part B based on your income. Some people who are eligible for Medicare and employer group health coverage choose to delay enrolling in Medicare Part B and Part D while still covered on their group health coverage (or their spouse’s group health coverage).

This saves them the premiums they would have paid for those parts. Your employer coverage already includes outpatient benefits so it may not be worth it to pay those Part B and D premiums.

When you DO delay Part B, your large group plan is considered creditable coverage. That means that you can enroll in Part B later without a late penalty when you decide to retire. Once you quit and leave the group plan, your insurance company will mail you a creditable coverage letter. Be sure you keep this. You will need it to show Medicare that you had other coverage so that you are not subject to late penalties for Parts B and D.

What Happens if You Retire and then Later Go Back to Work?

Also, many people ask us what happens if they retire, get Part B, and then later get a new job with employer insurance. You can cancel Part B at that time. Later, when you retire again, you’ll have a second 6-month Open Enrollment window to get a Medigap plan with no health questions asked.

A Word About COBRA

Medicare coordinates differently with COBRA than it does with active coverage. This is important because so many people get this wrong and then owe penalties.

When you are still actively working at a large employer, their Group Insurance pays primary and Medicare pays secondary.

The opposite is true of COBRA. Medicare pays first and COBRA pays second.

So, if you have COBRA and then become eligible for Medicare, usually at age 65, then you must enroll in Part A and B during your Initial Enrollment Period. Your COBRA typically ends when your Medicare begins. Failure to enroll during your IEP will result in a lifelong penalty. However, your dependents can keep COBRA for up to 3 years, even if you enroll in Medicare.

If you work past age 65 and then you retire, you are allowed to enroll in COBRA. You must also enroll in Part B no later than your 8th month on COBRA insurance, even if COBRA continues beyond that because Medicare pays primary and COBRA pays secondary. However, it’s recommended you enroll in Part B as soon as you become eligible for Medicare. If you don’t, your COBRA may not pay its share since it’s secondary to Medicare. Failure to enroll in Medicare by the 8th month can result in a permanent late enrollment penalty for Part B. Even worse, it could delay your Medicare Part B. You do not want to find yourself in a situation where you have to wait months to buy Part B during the next General Enrollment Period.
There is one exception for people with End-Stage Renal Disease. If you have ESRD, your COBRA will pay primary during a special 30-month coordination period between Medicare and COBRA.

The Option to Choose Medicare as your Primary Insurance

People with large group employer insurance also have another option. You can leave your group health plan and choose Medicare as your primary insurance, and then add a Medigap plan. This can often be cheaper for you or your spouse. For many people, it will also reduce your deductible spending and eliminate all doctor copays.

Whether this is cost-effective depends on how much your employer coverage costs you each month in your payroll deductions. Your plan deductible, copays, and your medication usage also are factors. If you are married and one spouse is younger, you must also consider the cost of health insurance for the spouse of the Medicare recipient.

May River Medicare Insurance can help you decide if you should enroll in Part B now or later. We often meet people that we advise to stay with their group plan for now because it's more advantageous for them.

You can investigate more about your options for Medigap or Medicare Advantage plans here.

Medicare and Employer Coverage Small Companies With Under 20 Employees

Medicare is primary if you are age 65 or older and your employer has fewer than 20 employees. You will need both Part A & B for sure because Medicare will pay first, and then your group insurance will pay secondary. Occasionally we see some insurance companies who will cover claims even if you don’t have Part B. Don’t buy it. You run the risk of that insurance company changing that at any time without warning, and leaving you stuck with all the expenses that Part B would normally cover. It’s not worth the risk – we advise always enrolling in Parts A & B if your employer has fewer than 20 employees and Medicare will be primary. However, you may be able to delay enrolling in a Part D drug plan without penalty if your group plan has RX benefits, as most do. Be sure to compare costs. It is sometimes cheaper to leave the group insurance altogether and enroll in a Medicare supplement as your secondary instead.

The HSA Exception

If you enroll in Medicare Part A and/or B, you can no longer contribute pre-tax dollars to your HSA. This is because to contribute pre-tax dollars to an HSA you cannot have any health insurance other than an HDHP. The month your Medicare begins, your account overseer should change your contribution to your HSA to zero dollars per month. However, you may continue to withdraw money from your HSA after you enroll in Medicare to help pay for medical expenses, such as deductibles, premiums, copayments, and coinsurances. If you use the account for qualified medical expenses, its funds will continue to be tax-free.

Whether you should delay enrollment in Medicare so you can continue contributing to your HSA depends on your circumstances. If you work for an employer with fewer than 20 employees, you may need Medicare in order to have primary insurance, even though you will lose the tax advantages of your HSA. This is because health coverage from employers with fewer than 20 employees pays secondary to Medicare. If you work at this kind of employer and fail to enroll in Medicare, you may have little or no health coverage because your health plan does not have to pay until after Medicare pays. Health coverage from an employer with 20 or more employees pays primary to Medicare, so you may choose to delay Medicare enrollment if you work at this kind of employer and continue putting funds into your HSA.

Note: In either case, you have access to the Part B Special Enrollment Period (SEP) when you lose coverage or retire.
If you choose to delay Medicare enrollment because you are still working and want to continue contributing to your HSA, you must also wait to collect Social Security retirement benefits. This is because most individuals who are collecting Social Security benefits when they become eligible for Medicare are automatically enrolled into Medicare Part A. You cannot decline Part A while collecting Social Security benefits. The takeaway here is that you should delay Social Security benefits and decline Part A if you wish to continue contributing funds to your HSA. Finally, if you decide to delay enrolling in Medicare, make sure to stop contributing to your HSA at least six months before you do plan to enroll in Medicare. This is because when you enroll in Medicare Part A, you receive up to six months of retroactive coverage, not going back farther than your initial month of eligibility. If you do not stop HSA contributions at least six months before Medicare enrollment, you may incur a tax penalty. If you require counseling around HSAs, consult a tax professional.

Frequently Asked Questions

Can my employer pay my Medicare Part B premium?

In terms of your employer actually writing a check for your Medicare Part B premiums when Social Security invoices you for Part B, generally no.However, employers can form a Section 105 Medical Reimbursement Plan, which will enable them to set funds aside for workers to use toward health insurance and dental insurance for their employees and families. This includes Medicare Part B premiums. A Section 105 plan allows tax-free reimbursement of the employee’s medical and other insurance expenses.

One popular type of Section 105 plan is a Health Reimbursement Arrangement or HRA. It is designed to reimburse eligible employees for their individual health insurance premiums and other qualified medical expenses.

Can your employer pay your Medigap premium?

May River Medicare Insurance often gets asked about whether an employer can pay for your Medigap plan. This idea might appeal to both you and your employer. It’s often expensive for your employer to carry older employees on the group plan, and you are likely to get more comprehensive coverage with Medicare and a Plan F or G Medigap plan.

However, this would violate CMS rules. If you reject your employer’s group insurance plan to choose Medicare primary, the employer cannot pay your Medigap premiums on an individual basis. One exception would be if the employer sets up a section 105 reimbursement plan for their group as a whole.

A Section 105 Reimbursement Plan allows the employer to deduct expenses for employees who purchase individual health insurance plans. Eligible employees can participate and the employer can reimburse premiums for Medicare Parts A and B as well as Medigap plans. Check with your employer to see if they have a Section 105 plan in place.

Can my employer kick me off my group health insurance when I turn 65?

It’s illegal for an employer to force any actively working employee to choose Medicare instead of their group health plan. You have the option to leave the group health plan and choose Medicare as your primary insurance instead, but your employer cannot make you do so.

Understand that if you are on retiree coverage from a former employer where you are no longer actively working, the employer does not have to provide a retiree plan for former employees after age 65. If that former employer DOES offer coverage, your benefits will likely change when you turn 65. This is because when you are age 65 and have retiree coverage, Medicare becomes your primary insurance, and your group coverage now pays secondary.

Prices and benefits from your employer coverage may be different once you turn 65. For example, if their retiree plan for people age 65 and older is a Medicare Advantage plan, then you will need to choose whether you want to enroll in that at 65 or switch to Original Medicare as your coverage. There are many factors to consider, such as premiums, how the plan covers your medications, and whether you have a younger spouse that needs to stay on your plan.

Can you enroll in a Medigap plan even if you have employer coverage at a large employer, just to be sure?

A Medigap cannot pay for anything unless Medicare is your primary insurance. The insurance company’s application will ask if you are still employed. When they see that you have large group coverage, they may reject your application because they know it will be of no use to you and it would be pointless to waste money on a policy you can't use. Medicare and employer coverage will be good enough coverage.

Retiree Coverage

If your company offers retiree coverage after you have stopped actively working, Medicare is primary to that coverage. Speak with the administrator of your retiree coverage to find out the costs for maintaining that coverage. If costs are high, you might consider leaving the retiree coverage for a Medigap and Part D drug plan instead.

Key Takeaways

If you have creditable employer coverage, you can still choose to leave that coverage and enroll in Medicare as primary instead. Ultimately, it depends on what is more cost-effective for you. Be aware of when you’ll need to stop contributing to your HSA account if you have one. This depends on if you delay Medicare past your Initial Enrollment period or not.

Where to Start

So can you have private insurance and Medicare? Yes, but there are many factors to consider. Deciding all of these things requires some careful cost benefit analysis between the costs for Medicare and the costs, copays and deductibles of your group coverage as well as the benefits for each. May River Medicare Insurance can you walk through the process and advise you on the parts you need to consider. If it makes sense for you to stay with your employer coverage, we’ll be the first to tell you.

This website has additional reading about Medicare coordination. See our posts for Medicare and Employer coverage for employer plans with less than 20 people. We also have a Medicare coordination of benefits post for employer plans with more than 20 people.

Still a bit confused? Call a licensed May River Medicare Advocate today at 843=227-6725. We will Educate, Empower and Enroll you in the right plan at the right time in the right way

Medicare and Employer Coverage