Medicare and Your JobEmployer plans, COBRA, HSAs and retiree coverage at 65

Employer coverage after 65: who pays first and when to sign up for Part B

The 20-employee rule, how primary and secondary payers work, and when delaying Part B is safe because of creditable job-based coverage.

If you keep working past 65, your job's health plan and Medicare may work together. The size of the employer decides who pays first.

Your situationWho pays firstPart B needed at 65?
Active job, employer with 20+ workersEmployer planUsually can delay without penalty
Active job, employer with fewer than 20 workersMedicareYes, usually required
Retiree coverageMedicareYes
COBRAMedicareYes; COBRA does not prevent the penalty
Spouse's active job, 20+ workersEmployer planUsually can delay

Delaying Part B safely

If your coverage is based on current employment at an employer with 20 or more workers, you can delay Part B. When the job or coverage ends, you have an 8-month Special Enrollment Period. Use form CMS-40B with CMS-L564 completed by the employer. Miss it and you face a lifetime penalty.

Part A while working

Most people take premium-free Part A at 65 even while working. But if you contribute to an HSA, see HSAs and Medicare first.

Compare costs

Sometimes Medicare plus a Medigap plan costs less than staying on an expensive employer plan, especially for a spouse. Compare the full premium and deductible. In Washington and Florida, Maru Insurance can compare Medicare options against your employer plan.

Questions people ask

Can I delay Part B if I'm working?

Usually yes, if the employer has 20+ workers and coverage is from current employment.

Does COBRA count?

No. COBRA does not let you delay Part B without penalty.

How long is the Special Enrollment Period?

Eight months after employment or coverage ends.

Who pays first at a small employer?

Medicare, for employers with fewer than 20 workers.

Independent educational site. Not affiliated with or endorsed by the U.S. government, the federal Medicare program, or any insurance company. Figures are 2026 amounts published by CMS unless noted; check Medicare.gov for your situation.