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Have Medicare’s enrollment rules changed in response to the coronavirus?

Josh Schultz | May 20, 2020

Reviewed by our health policy panel.

Q: Have Medicare’s enrollment rules changed in response to the coronavirus?

A: You may have read about health insurers allowing mid-year enrollment and other insurance changes due to the coronavirus, and wondered what the changes mean for your Medicare coverage. The Centers for Medicare and Medicaid Services (CMS) has approved two special enrollment periods due to the coronavirus – meaning you’ll be able to change your Medicare Advantage or Part D coverage, or enroll in Medicare for the first time if you missed your initial enrollment period (IEP), Part B special enrollment period (SEP), or the general enrollment period (GEP).

What changes can I make to my Medicare coverage because of the coronavirus?

On May 5, 2020, CMS announced that if you were unable to change your Medicare coverage during Medicare Advantage open enrollment or missed a different enrollment window because of the public health emergency, you can change your coverage during a SEP that lasts until June 30, 2020. During this SEP, you can enroll in or change your Medicare Advantage or Part D coverage, or return to Original Medicare.

In order to enroll in Medicare Advantage, you first have to have Medicare Part A and B (and you need either Part A or B to enroll in a Part D plan). Social Security is allowing people to enroll in Medicare Part B or premium Part A if they missed their IEP, GEP, or SEP because Social Security offices were closed. You’ll need to ask to be enrolled by June 17, 2020, and can do this by mail or fax. Your effective date will be determined as if you had enrolled during the proper period. You may have to pay additional Part B premiums depending on how far back you want Part B coverage to take effect. (Most people will use this opportunity to enroll in Medicare, but you’re also allowed to opt out of Part B if you were automatically enrolled in it.)

Allowing enrollment in Part B and premium Part A outside the normal windows is known as ‘equitable relief.’ We discuss that more here.

Can I enroll in Medicare if I've lost my job?

People were able to enroll in Medicare if they lost employer-sponsored coverage even before CMS announced the two coronavirus-related SEPs. This is because losing employer-sponsored insurance qualifies you for an SEP to enroll in Medicare Part B, and then into a Medicare Advantage or Part D plan. You may also be able to purchase a Medigap plan if you choose to have Original Medicare.

These existing enrollment options will be important once Medicare’s coronavirus-related SEPs end in June. The new SEPs also do not affect your eligibility to purchase Medigap coverage, meaning the guaranteed issue right described in this article continues to apply.

Medicare Part A and Part B enrollment if you’ve lost your job

Before you can enroll in either Medicare Advantage or Medigap, you must have both Medicare Part A and B. Most people can enroll in Part A anytime, but you need to enroll in Part B within eight months of losing job-based coverage (or your job, whichever ends first). If you don’t enroll during the Part B SEP, you’ll have to wait until the general enrollment period and coverage will be delayed.

You enroll in Part A and Part B through the Social Security Administration. If you’re enrolling in Medicare for the first time and don’t yet have Part A or B, you can enroll in both online. You can also enroll in Part A but delay Part B, although this is not recommended unless you still have coverage through a current employer (your own or your spouse’s) or you’re a federal retiree.

You’ll need to provide documentation if you’re using the Part B SEP, and won’t be able to submit this online. Social Security offices are closed during the emergency, so you can’t visit one to enroll in Medicare, but you can fax or mail your enrollment forms instead.

Social Security has posted the Part B enrollment request form (CMS 40B) and the request for employment information form (CMS L564) you’ll need for the Part B SEP on its website. It’s best if your employer can complete Section B of form L564 specifying the dates you worked there. If they’re unable to fill out the form, Social Security will accept the following items as evidence you had job-based coverage:

  • Income tax forms showing you paid health insurance premiums;
  • W-2s or pay stubs showing pre-tax medical insurance premiums withheld;
  • health insurance cards with a policy effective date;
  • explanations of benefits; or
  • statements or receipts showing you paid health insurance premiums.

If you’re enrolling by mail, keep copies of what you submit. You can find the mailing address for your local Social Security office using this online tool. Social Security’s fax number for Medicare enrollments is 1-833-914-2016.

Can I enroll in Medigap if I’ve lost my job-based coverage?

Medicare beneficiaries 65 and older have a six-month-long open enrollment period after Part B begins to enroll in any Medigap plan, without medical underwriting. If you were actively working after turning 65 and your employer had less than 20 employees, you would have needed to enroll in both Part A and B, because your employer-sponsored plan would have only paid after Medicare paid its share of your costs.

Although this means your Medigap open enrollment period is probably over, you’re not out of options. Because your employer-sponsored coverage was secondary to Medicare, you qualify for a guaranteed issue right to purchase other supplemental coverage, and have two months before and up to 63 days after your employer-sponsored plan ends to enroll in most Medigap plans (any Plan A, B, C, D, F, G, K, or L offered in your state, although Plans C and F are only available to people who first became eligible for Medicare prior to 2020).

(Although it is less common, some people combine Original Medicare with employer-sponsored coverage that pays before Medicare does, usually because they like the protection this provides from out-of-pocket costs or they didn’t intend to enroll in Part B. If you had coverage through a large group health plan, it would have paid before Medicare, and you would not qualify for this Medigap guaranteed issue right.)

Unfortunately, federal guaranteed issue rights are not available to people under 65. Your state may require insurers to offer some plans to disabled enrollees under certain circumstances, including job loss.

Can I enroll in Medicare Advantage and Part D if I lost job-based coverage?

If your employer-sponsored coverage is ending, you have an SEP to join a Medicare Advantage or Part D plan or switch to a different plan. The SEP ends two months after your employer plan or COBRA ends. If you use this SEP, you can choose an effective date for Medicare Advantage or Part D coverage up to three months in the future. (You have to already have both Part A and Part B to enroll in Medicare Advantage.)

Changing coverage if you’re treated in a skilled nursing facility

If you contract the coronavirus and are moved to a skilled nursing facility to recover, you have an SEP to enroll in a different Medicare Advantage or Part D plan or switch from an Advantage plan to Original Medicare. This opportunity to change your coverage lasts as long as you’re hospitalized and ends two months afterward.

Josh Schultz has a strong background in Medicare and the Affordable Care Act. He coordinated a Medicare ombudsman contract at the Medicare Rights Center in New York City, and represented clients in extensive Medicare claims and appeals.

In addition to advocacy work, Josh helped implement federal and state health insurance exchanges at the technology firm hCentive. He also has held consulting roles, including as an associate at Sachs Policy Group, where he worked with insurer, hospital and technology clients on Medicare and Medicaid issues.

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