WORKING PAST 65
Can I Delay Medicare If I’m Still Working Past 65?
Sometimes—but being employed does not automatically make it safe to delay Medicare. Your coverage usually needs to come from your or your spouse’s current employment, and employer size, who pays first and whether you contribute to an HSA can all change the answer.
If you plan to work beyond age 65, you may not need to enroll in every part of Medicare immediately. Many people with qualifying employer group coverage can delay Medicare Part B without a late-enrollment penalty.
The dangerous part is assuming that any job or health insurance makes delaying safe. The source of the coverage, the size of the employer and the way the group plan coordinates with Medicare matter. A mistake can leave you with unpaid medical bills, a gap in coverage or a penalty that follows you for as long as you have Part B.
This guide focuses on people becoming eligible for Medicare at 65. Different coordination rules can apply when Medicare eligibility is based on disability or End-Stage Renal Disease.
THE SHORT ANSWER
When Can You Usually Delay Medicare Part B?
You may be able to delay Part B when:
- You or your spouse is actively working;
- You are covered by a group health plan from that current employment; and
- The employer plan will remain your primary coverage after you become eligible for Medicare.
For someone who is 65 or older, the employer’s size is often the key coordination question.
| Your situation | Who generally pays first? | What it usually means |
|---|---|---|
| Current-employment group coverage from an employer with 20 or more employees | The employer group plan | You may be able to delay Part B while that coverage and current employment continue. |
| Current-employment group coverage from an employer with fewer than 20 employees | Medicare | You will generally need Part A and Part B at 65 so the employer plan can coordinate correctly. |
| COBRA, retiree coverage, Marketplace coverage or an individual policy | Varies, but the coverage is not based on current employment | Do not rely on it by itself to delay Part B or preserve the current-employment Special Enrollment Period. |
Multi-employer plans and a few other situations can follow different rules. The number of people at your particular worksite may not be the number that controls. Ask the benefits administrator how the plan coordinates with Medicare—not simply whether you are allowed to remain enrolled.
Medicare’s “Who pays first?” tool can help you review the general coordination rule for your situation.
The penalty question and the claims question are different
Coverage through current employment may eventually give you a Special Enrollment Period for Part B. That does not necessarily mean the employer plan will pay correctly if you delay Medicare.
For example, a small-employer plan may pay as though Medicare already paid first. If you do not actually have Medicare, the group plan may leave a large part of the bill unpaid. That is why employer size and payer order must be confirmed before you decline or delay Part B.
PART A, PART B AND PART D
Do You Delay All of Medicare—or Only Part B?
Medicare is not one single enrollment decision. Part A, Part B and prescription coverage require separate consideration.
Medicare Part A
Most people qualify for premium-free Part A. Some enroll in Part A at 65 even while keeping employer coverage, but that is not always the right move. Enrollment in any part of Medicare ends your eligibility to contribute to a Health Savings Account.
If you want to continue making HSA contributions, you may need to delay premium-free Part A as well as Part B. This requires advance planning because Part A can begin retroactively for up to six months when someone enrolls after 65, but not earlier than the first month of Medicare eligibility. Read the complete Medicare and HSA contribution guide.
Medicare Part B
Part B has a monthly premium, so it is the part people most commonly consider delaying while they have qualifying coverage from current employment. Before delaying, confirm that the group plan remains primary and that you will qualify for the Part B Special Enrollment Period later.
Medicare Part D
You can generally delay Part D while you have creditable prescription drug coverage—coverage expected to pay, on average, at least as much as standard Medicare drug coverage. Your employer or plan should provide a creditable-coverage notice each year. Keep every notice with your records.
Going 63 consecutive days or more without Part D or other creditable drug coverage can trigger a Part D late-enrollment penalty. Learn more in our Medicare Part D guide.
The HSA trap
You and your employer cannot contribute to your HSA for months in which you are enrolled in Medicare. Because delayed premium-free Part A can be retroactive, Medicare advises people with an HSA to stop contributions six months before retiring or applying for Social Security or Railroad Retirement benefits. Coordinate the dates with the employer’s benefits team and a qualified tax professional.
COVERAGE THAT DOES NOT COUNT THE SAME WAY
Being Insured Does Not Always Mean You Can Delay Medicare
The Part B Special Enrollment Period for people working past 65 is tied to group health coverage based on current employment. These types of coverage should not be treated as substitutes without checking their separate Medicare rules:
- COBRA: COBRA does not extend the current-employment Part B enrollment window. The eight-month clock generally starts when the active employment or its group coverage ends, even if COBRA continues. See COBRA and Medicare Part B timing.
- Retiree insurance: Retiree coverage may require Medicare to pay first and may reduce or deny payments if you do not have Parts A and B.
- Marketplace or individual coverage: This is not group coverage based on current employment and generally does not protect you from a Part B late-enrollment penalty.
- VA health care: VA benefits and Medicare generally pay through separate systems. VA coverage by itself does not create the same Part B Special Enrollment Period as current-employment group coverage.
- Coverage bought with an employer stipend: An individual policy does not necessarily become an employer group health plan merely because an employer helps pay for it.
If you are unsure what type of coverage you have, ask the insurer whether it meets the federal definition of employer group health plan coverage based on current employment.
WHEN THE JOB OR COVERAGE ENDS
How the Part B Special Enrollment Period Works
If you delayed Part B because you had qualifying coverage through your or your spouse’s current employment, you can generally enroll:
- At any time while the current employment and group coverage continue; or
- During the eight-month period after the employment or the group coverage ends, whichever happens first.
Do not plan to use all eight months. That window concerns Part B, but the opportunity to join Medicare Advantage or Part D after employer or union coverage ends generally lasts for only two full months after the month the coverage ends. Waiting can also create a gap between the employer plan and Medicare. Use the full retiring-after-65 Medicare transition checklist.
Stopping work can also reduce the income Social Security uses to set future Medicare premiums. If an older tax return causes IRMAA after retirement, review how to request a new IRMAA determination with Form SSA-44.
If you want Medicare to begin when the employer insurance ends, Medicare recommends signing up for Part B about a month before the job-based coverage ends. Social Security handles enrollment in Parts A and B.
Two forms commonly used when enrolling in Part B after working past 65 are:
- CMS-40B: Application for Enrollment in Medicare Part B; and
- CMS-L564: Request for Employment Information, which documents the group coverage based on current employment.
Social Security decides which documents are required. CMS provides the current CMS-L564 form and instructions.
For the larger enrollment timeline, read When to Sign Up for Medicare.
BEFORE YOU DELAY
Six Questions to Ask the Employer
- Is my coverage based on my or my spouse’s current employment?
- How many employees count under the Medicare coordination rules?
- After I turn 65, does the employer plan pay before or after Medicare?
- Do I need Part A or Part B for the employer plan to pay correctly?
- Is the prescription coverage creditable for Part D?
- How will changing coverage affect my spouse or other dependents?
Ask for the answers in writing and keep the plan’s Summary Plan Description and annual creditable-coverage notices. A verbal “you can stay on the plan” does not answer whether the plan expects Medicare to pay first.
If your retirement will end coverage for a spouse or dependent, review what happens to a spouse’s health insurance when you retire and start Medicare.
Then compare the actual costs
Even when you are allowed to delay Part B, keeping the employer plan is not automatically the least expensive choice. Compare:
- The employee premium and any premium charged for a spouse;
- The deductible, copays, coinsurance and maximum out-of-pocket limit;
- Doctor, hospital and pharmacy access;
- Prescription coverage;
- HSA contributions from you and the employer; and
- The cost of Medicare plus the private coverage you would choose after enrolling.
If Medicare is the better route, the next decision is usually between Medicare Advantage and Original Medicare with a Medicare Supplement and Part D plan. If you choose Original Medicare, understand when your six-month Medigap Open Enrollment Period begins. See our Medicare Advantage vs. Medicare Supplement comparison.
PENALTIES AND GAPS
What Happens If You Delay Without Qualifying Coverage?
If you do not qualify for a Special Enrollment Period, the Part B late-enrollment penalty is generally 10% for each full 12-month period you could have had Part B but did not. In most cases, the penalty is added to your Part B premium for as long as you have Part B.
You may also need to use the General Enrollment Period and wait for coverage to begin. The financial risk is therefore not only the penalty—it is the possibility of months without the coverage you expected.
The safest rule is simple: do not delay Medicare because someone casually told you that working past 65 is enough. Verify the source of the insurance, payer order, employer size, drug coverage and HSA consequences first.
COMMON QUESTIONS
Working Past 65 and Medicare FAQ
Can I delay Medicare if I am covered through my spouse’s job?
Possibly. Coverage through a spouse’s current employment can support a Part B Special Enrollment Period. You still need to confirm employer size, payer order and the group plan’s requirements.
Can I delay only Part B?
Many people with qualifying large-employer coverage take premium-free Part A and delay Part B. However, enrolling in Part A ends HSA contribution eligibility, and delayed Part A may be retroactive. Someone who wants to keep contributing to an HSA may need to delay Part A too.
What if my employer has exactly 20 employees?
For Medicare eligibility based on age, current-employment group coverage from an employer with 20 or more employees generally pays first. Confirm the plan’s official employee count and coordination rules with the benefits administrator.
Can I wait until COBRA ends to enroll in Part B?
Usually not safely. COBRA does not extend the eight-month Part B Special Enrollment Period based on current employment. That clock generally begins when the employment or active-employment group coverage ends, even if you elect COBRA.
Do I have to start Social Security to enroll in Medicare?
No. You can apply for Medicare without starting monthly Social Security retirement benefits. If you are already receiving Social Security, review any automatic Medicare enrollment carefully before making HSA contributions or declining Part B.
Can a Medicare broker enroll me in Part A and Part B?
No. Social Security—or the Railroad Retirement Board for qualifying railroad beneficiaries—handles Parts A and B enrollment. A broker can help you organize the timing questions and compare the Medicare Advantage, Medicare Supplement and Part D choices that follow.
WORKING PAST 65 SERIES
Continue the Retirement-to-Medicare Series
These guides divide one complicated transition into separate decisions about delaying Medicare, retiring, HSA contributions, COBRA and a spouse’s coverage.
OFFICIAL INFORMATION
Medicare enrollment and coordination resources
CLEAR ANSWERS BEFORE YOU RETIRE
Review Your Medicare Timing Before You Decline Part B
Thompson Medicare Brokerage helps people in Missouri and Illinois understand how employer coverage, retirement dates and Medicare plan choices fit together. We can help you organize the right questions and compare the private Medicare coverage options we represent.
Social Security and Medicare make the official eligibility and enrollment decisions. Your employer or group plan must confirm how its coverage coordinates with Medicare.
Thompson Medicare Brokerage is not connected with or endorsed by the U.S. government or the federal Medicare program. This article provides general educational information and is not tax or legal advice. Coverage coordination and enrollment eligibility depend on the facts of your situation.