Working Past 65: Do You Need to Sign Up for Medicare?

Turning 65 does not necessarily mean you must leave your employer health insurance or enroll in every part of Medicare immediately. If you or your spouse are still working and you have health coverage based on current employment, your Medicare enrollment options can depend on the type of coverage you have and how that coverage coordinates with Medicare.

Quick answer: Some people with qualifying employer group health coverage based on current employment can delay Medicare Part B without a late-enrollment penalty. However, the rules depend on your situation, including the employer providing the coverage. COBRA and retiree coverage are not treated the same as coverage based on current employment for Medicare Part B enrollment purposes.

For a broader overview of Medicare coverage, costs, plan options and enrollment, see our complete guide to Medicare in California.

Do You Have to Sign Up for Medicare at 65 if You're Still Working?

Not necessarily.

If you or your spouse are actively working and you have group health insurance through that current employment, you may be able to delay Medicare Part B and enroll later during a Special Enrollment Period.

However, having health insurance does not automatically mean you should delay Medicare.

Before making an enrollment decision, determine how your employer coverage coordinates with Medicare and whether Medicare would be the primary or secondary payer.

What Happens to Employer Health Insurance When You Turn 65?

Becoming eligible for Medicare does not automatically cancel employer-sponsored health insurance.

Many people continue employer coverage after turning 65 because they or their spouse are still actively working.

The important question is how that employer plan coordinates with Medicare.

Depending on the circumstances, the employer plan may pay first and Medicare second, or Medicare may pay first and the employer plan second.

This can affect whether delaying Medicare enrollment could leave you with unexpected gaps in coverage.

Does Employer Size Matter for Medicare?

Employer size can affect which coverage pays first when someone becomes eligible for Medicare because of age.

For many people age 65 or older who have group health coverage through current employment, Medicare coordination rules distinguish between employers with 20 or more employees and employers with fewer than 20 employees.

When the employer has 20 or more employees, the employer group health plan generally pays first and Medicare pays second for someone eligible for Medicare because of age.

When the employer has fewer than 20 employees, Medicare generally pays first and the employer plan pays second, although specific circumstances and plan arrangements can affect how the rules apply.

Because of this distinction, someone working for a smaller employer should not assume that employer insurance alone allows Medicare enrollment to be delayed without affecting coverage.

Should You Enroll in Medicare Part A While Still Working?

Many people qualify for premium-free Medicare Part A because they or their spouse paid Medicare taxes for a sufficient period while working.

Some people choose to enroll in premium-free Part A at 65 even while continuing employer coverage, but this decision requires additional consideration if you contribute to a Health Savings Account, or HSA.

Medicare enrollment can affect your eligibility to contribute to an HSA.

Medicare and Health Savings Accounts

Once you are enrolled in Medicare, you generally cannot continue contributing to a Health Savings Account.

This includes enrollment in Medicare Part A.

There is another important issue for people who enroll in Medicare after age 65. In certain circumstances, premium-free Part A coverage can begin retroactively for up to six months, but not earlier than the first month you were eligible for Medicare.

Because of this retroactive coverage, people working past 65 who contribute to an HSA should carefully consider the timing of their Medicare enrollment and HSA contributions.

HSA contribution and tax rules can be complex, so questions about the tax treatment of HSA contributions should be reviewed with an appropriate tax professional.

Can You Delay Medicare Part B While Working?

Some people can delay Medicare Part B without a late-enrollment penalty while they have qualifying group health coverage based on current employment.

This may apply when the coverage is through your own current employment or your spouse's current employment.

When that qualifying employment or coverage ends, a Special Enrollment Period may allow you to enroll in Part B without waiting for the General Enrollment Period.

See our guide to Medicare enrollment and when to sign up for a broader explanation of Medicare enrollment periods.

What Is the Part B Special Enrollment Period?

If you delayed Part B because you had qualifying group health coverage based on current employment, you may generally enroll in Part B while you still have that coverage or during an eight-month Special Enrollment Period after the employment or qualifying group health coverage ends, whichever happens first.

This Special Enrollment Period can allow eligible individuals to enroll without the Part B late-enrollment penalty that might otherwise apply.

Waiting until the end of the eight-month period can still create a gap in health coverage, so people preparing to retire often begin the Medicare enrollment process before their employer insurance ends.

Does COBRA Count as Current Employer Coverage?

No. COBRA continuation coverage is not treated the same as group health coverage based on current employment for purposes of the Medicare Part B Special Enrollment Period.

If your employment or qualifying current-employment coverage ends, your eight-month Part B Special Enrollment Period generally begins even if you elect COBRA.

COBRA does not extend the eight-month Part B enrollment window.

This means waiting until COBRA coverage ends before enrolling in Medicare can potentially result in a coverage gap or late-enrollment penalty.

What About Retiree Health Insurance?

Retiree health coverage is also different from insurance based on current employment.

Some retiree plans are designed to work with Medicare and may require you to enroll in Medicare Part A and Part B for the retiree plan to provide its intended benefits.

Retiree coverage generally does not provide the same Part B Special Enrollment Period protection as group health coverage based on current employment.

Review the rules of the specific retiree plan and Medicare enrollment requirements before delaying Medicare.

What if Your Spouse Is Still Working?

You may have Medicare enrollment options if you are covered under a group health plan through a spouse who is still actively working.

Qualifying coverage through a spouse's current employment can potentially allow you to delay Part B and later use a Special Enrollment Period.

The employer and coverage still need to meet the applicable Medicare requirements.

Coverage through a spouse who has retired is not the same as coverage through a spouse's current employment.

What if You Have Coverage Through Your Own Job?

If you continue working after 65 and have group health insurance through your current employer, determine how the plan coordinates with Medicare before deciding whether to enroll in or delay Part B.

Ask your employer or benefits administrator:

• Is this coverage based on my current employment?
• Does the employer plan pay before or after Medicare?
• Do I need Medicare Part A or Part B for the employer plan to pay correctly?
• Is the prescription drug coverage considered creditable for Medicare Part D?
• How will Medicare enrollment affect my HSA eligibility, if applicable?

Can You Delay Medicare Part D While Working?

You may be able to delay Medicare Part D without a late-enrollment penalty if your employer prescription drug coverage is considered creditable coverage.

Creditable prescription drug coverage is coverage that is expected to pay, on average, at least as much as Medicare's standard prescription drug coverage.

Your employer or health plan should provide information indicating whether your prescription coverage is creditable.

Keep any creditable coverage notices you receive.

If you go 63 consecutive days or more without Medicare drug coverage or other creditable prescription drug coverage after the applicable enrollment period, a Part D late-enrollment penalty may apply.

Learn more in our guide to Medicare Part D and prescription drug coverage.

What Happens When You Retire After 65?

If you delayed Medicare while covered by qualifying insurance based on current employment, retiring is an important Medicare transition point.

Before your employer coverage ends:

• Confirm the date your employer insurance will terminate
• Determine when Medicare Part A and Part B should begin
• Complete any required Medicare enrollment forms
• Review prescription drug coverage
• Understand your Medicare coverage options after Part A and Part B begin

Starting the process before employer coverage ends can help reduce the risk of a gap in health insurance.

What Coverage Options Do You Have After Employer Insurance Ends?

After enrolling in Medicare Part A and Part B, you generally have two primary ways to receive Medicare coverage.

You can remain with Original Medicare, which consists of Part A and Part B, or you may be able to enroll in a Medicare Advantage plan.

People with Original Medicare may also consider separate Part D prescription drug coverage and Medicare Supplement Insurance, commonly called Medigap, if eligible.

See Original Medicare vs. Medicare Advantage to understand how the two approaches differ.

Does Losing Employer Coverage Give You Medicare Enrollment Rights?

Losing qualifying employer coverage can create Medicare Special Enrollment Period opportunities.

The enrollment periods that apply can differ depending on whether you are enrolling in Part B, Part D or Medicare Advantage.

Because each type of Medicare coverage can have its own deadlines, do not assume that one enrollment deadline applies to every part of Medicare.

What Should You Do Before Turning 65 While Still Working?

If you plan to continue working after 65, review your Medicare situation before your Initial Enrollment Period begins.

A useful checklist includes:

• Confirm whether your coverage is based on current employment
• Ask how the employer plan coordinates with Medicare
• Confirm whether Medicare would pay first or second
• Determine whether delaying Part B is appropriate under Medicare rules
• Confirm whether your prescription coverage is creditable
• Review HSA implications before enrolling in any part of Medicare
• Keep documentation showing your employer health coverage
• Understand what happens when employment or employer coverage ends

Frequently Asked Questions

Do I have to enroll in Medicare at 65 if I'm still working?

Not necessarily. Some people with qualifying group health coverage based on their own or a spouse's current employment may be able to delay Medicare Part B without a late-enrollment penalty.

Can I keep my employer health insurance after age 65?

In many situations, yes. However, you should determine how the employer plan coordinates with Medicare and whether Medicare is expected to pay first or second.

Does the size of my employer matter?

It can. For people eligible for Medicare because of age, Medicare coordination rules generally distinguish between employers with 20 or more employees and employers with fewer than 20 employees. Specific circumstances can affect how the rules apply.

Can I contribute to an HSA after enrolling in Medicare?

Generally, no. Once you are enrolled in Medicare, you generally cannot continue contributing to an HSA. Medicare Part A can also be retroactive in certain circumstances when enrollment occurs after age 65, which can affect HSA contribution timing.

Does COBRA let me delay Medicare Part B?

COBRA is not treated the same as group health coverage based on current employment for the Part B Special Enrollment Period. Electing COBRA generally does not extend the eight-month Part B enrollment window.

How long is the Part B Special Enrollment Period after employment ends?

For someone who qualifies based on current-employment group health coverage, the Part B Special Enrollment Period generally lasts eight months after the employment or qualifying coverage ends, whichever happens first.

Can I delay Part D while I'm working?

You may be able to delay Part D without a late-enrollment penalty if you maintain other creditable prescription drug coverage. Confirm whether your employer drug coverage is considered creditable.

Should I wait until I retire to start the Medicare enrollment process?

If you will need Medicare when employer coverage ends, beginning the enrollment process before retirement can help reduce the risk of a gap in health coverage.

This article is for general educational and informational purposes. Medicare enrollment, employer coordination, Special Enrollment Periods and HSA rules can vary based on individual circumstances and may change over time. Employers and health plans may also have their own coverage requirements. For official Medicare information, visit Medicare.gov or call 1-800-MEDICARE. For questions involving HSA tax rules, consult an appropriate tax professional.