Working Past 65
COBRA After 65: Does It Let You Delay Medicare Part B?
You leave your job at 66 and your employer offers COBRA. The coverage looks familiar, so it can seem reasonable to keep it and deal with Medicare later.
That's where an important Medicare rule can be missed.
COBRA may continue health coverage after employment ends, but Medicare does not treat COBRA the same way it treats group health coverage based on current employment when determining your Medicare Part B Special Enrollment Period.
Does COBRA let you delay Medicare Part B after 65?
COBRA by itself does not extend the Medicare Part B Special Enrollment Period tied to current employment.
Medicare specifically says COBRA and retiree health plans aren't considered coverage based on current employment for this purpose.
If you delayed Part B because you or your spouse were actively working and you had qualifying employer group health coverage, the important change is when that employment or qualifying coverage ends — not when COBRA eventually ends.
When does the 8-month Part B enrollment window start?
Medicare says the 8-month Special Enrollment Period generally begins when you or your spouse stop working or when the group health coverage based on that current employment ends, whichever happens first.
Choosing COBRA afterward does not restart that clock.
For example, if your employment ends and you elect COBRA, you shouldn't assume that you can wait until the end of COBRA and then receive a new eight months to enroll in Part B.
Why is this easy to misunderstand?
From the consumer's perspective, the health insurance may appear to continue. You may have the same insurance company, similar benefits, and even the same identification card.
Medicare is looking at something different: whether the group health coverage is based on current employment.
Once the employment relationship supporting that qualifying coverage ends, COBRA continuation coverage doesn't preserve the same Part B enrollment protection.
What if you already have Medicare Part A?
Some people enroll in premium-free Part A at 65 but delay Part B while continuing to work.
If that's your situation and your active employer coverage is ending, Medicare allows people who qualify for the Special Enrollment Period to add Part B after employer group health coverage based on current employment ends.
The mistake would be assuming that having Part A plus COBRA means you can wait until COBRA expires before dealing with Part B.
Can COBRA and Medicare exist at the same time?
In some situations, a person can have both Medicare and COBRA. But having both doesn't mean COBRA replaces Medicare or changes Medicare's enrollment deadlines.
How the coverage coordinates can depend on your circumstances and the COBRA plan. Medicare recommends checking with the benefits administrator or COBRA plan about how the coverage works with Medicare.
If you're considering COBRA because a spouse or dependent also needs coverage, that household situation can make the decision different from looking only at your own Medicare eligibility.
What if you're retiring and the employer offers retiree insurance instead?
Retiree health coverage creates a similar Medicare enrollment concern.
Medicare says retiree health plans aren't considered group health coverage based on current employment for the Part B Special Enrollment Period.
That doesn't mean retiree coverage has no value. It means you shouldn't assume that having retiree insurance gives you the same ability to postpone Part B that qualifying active-employment coverage may provide.
What happens if you wait until COBRA ends?
If your Part B Special Enrollment Period has already expired by the time COBRA ends, you may have to use another Medicare enrollment period.
Medicare warns that missing the applicable Part B enrollment window can result in a gap in coverage and may lead to a Part B late enrollment penalty.
That's why the employment-end date deserves attention before you decide how long to rely on COBRA.
Three dates to write down before choosing COBRA
If you're 65 or older and leaving employer coverage, identify these dates before making your decision:
- The date your or your spouse's current employment ends.
- The date the employer group health coverage based on that employment ends.
- The date you want Medicare Part B coverage to begin.
Then separately consider when COBRA begins and how it will coordinate with Medicare. Keeping those dates separate can prevent COBRA's end date from becoming the date you mistakenly use for Medicare enrollment.
COBRA is a coverage decision, not a Medicare enrollment extension
The simplest way to think about the issue is this: COBRA may continue health coverage, but it doesn't continue your status as an actively employed worker for Medicare Part B enrollment purposes.
Golden Milestone Services is an independent insurance agency that helps people understand their Medicare options when they're retiring, leaving employer coverage, or transitioning into Medicare. Assistance is available in both English and Hmong.
If you're leaving work after 65, start with the date your active employment and job-based coverage end. Understand your Medicare enrollment window first, then determine where COBRA fits into the rest of your coverage.
Common questions
Does COBRA count as employer coverage for delaying Medicare Part B?
Not for the Medicare Part B Special Enrollment Period based on current employment. Medicare says COBRA isn't considered group health coverage based on current employment.
When does my 8-month Medicare Part B Special Enrollment Period start if I choose COBRA?
The 8-month Special Enrollment Period generally begins when the current employment or qualifying employer group health coverage ends, whichever happens first. Choosing COBRA afterward doesn't restart the eight-month period.
Can I wait until COBRA ends to enroll in Medicare Part B?
Don't assume that you can. If your Part B Special Enrollment Period expires while you're on COBRA, COBRA ending doesn't create a new employment-based Part B Special Enrollment Period.
Does retiree health insurance let me delay Medicare Part B?
Retiree health coverage isn't considered coverage based on current employment for the employment-based Part B Special Enrollment Period. Review your Medicare timing when active employment coverage ends rather than waiting for retiree coverage to end.
Can I have Medicare and COBRA at the same time?
In some circumstances you can have both. How the two coverages work together can depend on your situation, so check with the COBRA plan or benefits administrator before making coverage decisions.
What forms may be needed when adding Part B after employer coverage ends?
Medicare says people signing up for Part B during the employment-based Special Enrollment Period provide proof to Social Security that they had group health coverage based on current employment. Medicare currently identifies forms CMS-40B and CMS-L564 for the paper process.