Medicare Enrollment Guidance for HR Managing Employees Over 65

This article provides critical guidance for human resource professionals managing employees who turn 65 and have ongoing employment with employer-sponsored health insurance. It addresses Medicare enrollment rules specifically for employees who continue working full-time while becoming eligible for Medicare. The key takeaway is that employees who are still working full-time should generally delay enrolling in Medicare Part B until their employment status changes. This delay helps avoid unnecessary Medicare premium payments when employer coverage is primary.

The article emphasizes the importance of understanding the Medicare Initial Enrollment Period (IEP) and the Special Enrollment Period (SEP). The IEP starts three months before and ends three months after the 65th birthday. If employment continues full-time, employees can defer Medicare Part B enrollment but must enroll during the SEP when their work status changes, retires, or is terminated to avoid coverage gaps or penalties.

HR managers are advised to review the Medicare & You handbook, particularly the sections detailing which payer (Medicare or employer) pays first based on company size and insurance type. For companies with over 100 employees, employer insurance generally remains primary. COBRA and retiree insurance do not provide a SEP for Medicare enrollment, which can lead to lapses in coverage if not managed properly.

In managing retiree transitions, HR should complete and sign CMS-L564 (Request for employment information) and attach it to CMS-40B (Medicare Part B application) to document eligibility for SEP. Filing promptly and advising employees to submit forms in person at the local Social Security office ensures timely Medicare Part B activation. This process also extends benefits to spouses covered under the employer plan losing coverage.

The article underscores the complexities of Medicare coordination with employer insurance and the pivotal role HR plays in advising employees during this transition. Ensuring compliance with enrollment timelines and documentation practices can minimize out-of-pocket costs and coverage gaps for aging employees. It further highlights the importance of staying informed about regulatory guidelines to handle these scenarios effectively.