Your Compliance Edge

Medicare and COBRA

There is often confusion among employers and employees regarding the integration of COBRA with Medicare.  First, there is a distinction between being “entitled” to Medicare and being “eligible” for Medicare. One is eligible for Medicare when he or she reaches 65.  One is entitled to Medicare when he or she actually enrolls in Medicare.

Eligibility for COBRA.  If a qualified beneficiary first becomes entitled to Medicare benefits after COBRA continuation coverage has been elected, the plan may terminate the qualified beneficiary's COBRA continuation coverage upon the date on which the qualified beneficiary becomes entitled to Medicare benefits.

By contrast, if a qualified beneficiary first becomes entitled to Medicare benefits and subsequently elects COBRA continuation coverage, then the qualified beneficiary's entitlement to Medicare benefits cannot be a basis for terminating his or her COBRA continuation coverage.


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