Medicare and Employer Coverage

Medicare coordinates benefits with your employer coverage

If you are 65 + (or turning 65 soon) and will have both Medicare and Employer Coverage too because you are still actively working, you 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 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 $3000 deductible. The Medicare Part A hospital deductible is $1364 in 2019. 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 $1364. 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 account 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 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 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.

Read more about coordination of your Medicare benefits and large employer coverage 

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 are  under 65 and on COBRA, then when you turn 65 you must enroll in Part A and B during your Initial Enrollment Period. You need to enroll because Medicare will be your primary coverage and COBRA only pays as secondary. Failure to enroll during your IEP will result in a lifelong penalty. You can keep COBRA if you like and let it pay secondary instead of a Medigap plan. Just be sure you don’t miss enrolling in both Part A and Part B during your Initial Enrollment Period, which begins 3 months before your 65th birthday month and ends 3 months after your 65th birthday month.

If you work past age 65 and then you retire, you must enroll in Part B no later than your 8th month on COBRA insurance, even if COBRA continues beyond that. Failure to do so can result in a permanent late enrollment penalty for Part B. Even worse, it could delay your Medicare Part B until July of the following year. You do not want to find yourself in a situation where you have to wait months to buy Part B.

The Option to Choose Medicare as your Primary Insurance

People will 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.


Medicare and Employer Coverage – Small Companies 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

Medicare and employer health insurance do not mix well if you are contributing to an HSA account. Beware of tax penalties if you contribute to an HSA.

One exception on either large or small employer coverage is HSA-compatible health plans. If you have a qualified high deductible health plan and you enroll in Medicare, you can no longer contribute to your health savings account.

You cannot contribute to a health savings account if you have ANY part of Medicare active. You also cannot accept any contributions from an employer if you have active Medicare.

So, if you work for a small employer, you must enroll in Parts A and B at 65 to avoid penalties. This means that if you plan to keep your HSA-qualified employer coverage, you must stop contributing into the HSA. Your spouse can still contribute if he or she is covered on your group plan and is not yet enrolled in Medicare.

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 the employees and family. 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?

We often get questions here at Boomer Benefits 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.

Be aware though 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 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?

This would be a waste of money. 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. 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.