PharmSurance Field Guide
Still Working
at 65? What You
Need to Know
If you or your spouse have employer coverage, you may be able to delay Medicare without penalty — but the rules are very specific. Getting this wrong can trigger a permanent late enrollment penalty.

Most people enroll in Medicare when they turn 65. But if you're still working — or your spouse is — you may have options. The key is understanding which types of coverage let you delay, and which do not. COBRA, retiree plans, and marketplace plans are not substitutes for Medicare.

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Still on Your Own Employer Plan
You are actively employed · coverage through your job
Can you delay Medicare?

Yes — you can generally delay Part B (and Part D) without penalty as long as you are actively employed and covered by your employer's group health plan.

The rules
  • Your employer must have 20 or more employees for Medicare to be the secondary payer
  • You must be actively employed — not retired, even if still receiving employer benefits
  • Your group coverage must be through your own current employment or your spouse's current employment
  • You typically still need to enroll in Part A at 65 — it's premium-free and doesn't hurt to have
  • If your employer has fewer than 20 employees, Medicare becomes primary and you should enroll
When your coverage ends
  • You get a Special Enrollment Period (SEP) — 8 months to enroll in Part B after your employer coverage ends or you stop working, whichever comes first
  • You also get 63 days to enroll in Part D without a penalty after losing creditable drug coverage
  • Don't wait until COBRA ends — the SEP clock starts when employer coverage ends, not COBRA
Covered Through a Spouse's Employer
Your spouse is still actively employed
Can you delay Medicare?

Yes — if your spouse is actively employed and you are covered under their employer's group health plan, you can delay Medicare Part B without penalty.

The rules
  • Your spouse must be currently and actively employed — retired spouses with continued benefits do not count
  • The employer must have 20 or more employees
  • You are covered as a dependent under their active group plan
  • Same SEP applies when your spouse's coverage ends — 8 months for Part B, 63 days for Part D
Important timing note
  • When your spouse retires or loses their job, notify Social Security promptly
  • Don't wait — the SEP window is strict and exceptions are rare
  • If your spouse's employer has fewer than 20 employees, Medicare should be your primary coverage
COBRA Coverage
Continuation coverage after leaving a job
Can you delay Medicare?

No — COBRA does NOT let you delay Medicare enrollment. This is one of the most common and costly mistakes people make at 65.

Why COBRA doesn't count
  • COBRA is continuation coverage — it's not the same as active employer coverage
  • Medicare considers your employment to have ended when you left the job
  • Your 8-month SEP window starts when you leave work — not when COBRA ends
  • If you rely on COBRA past your 8-month SEP window, you will face a late enrollment penalty for Part B — permanently
  • A separate permanent Part D penalty applies too, based on how long you went without coverage
What to do instead
  • Enroll in Medicare Part B within 8 months of leaving your job
  • You can keep COBRA for coverage categories not included in your Medicare plan
  • Talk to an advisor before your last day of work to plan the transition
Retiree Health Coverage
Former employer continues benefits after retirement
Can you delay Medicare?

Generally no — retiree coverage is not a substitute for Medicare. Most retiree plans are designed to work alongside Medicare, not replace it.

What you need to know
  • Retiree plans typically become secondary to Medicare once you're eligible
  • If you delay Medicare, your retiree plan may not pay your claims as primary — leaving you with large bills
  • Some retiree plans will cancel your coverage entirely if you don't enroll in Medicare when eligible
  • Check with your former HR department or benefits administrator before making any decision
The exception
  • Some retiree plans explicitly allow delayed Medicare enrollment and remain primary — but these are rare
  • Get it in writing from your plan administrator if this applies to you
ACA Marketplace Plan
Individual coverage purchased through Healthcare.gov
Can you delay Medicare?

No — a marketplace plan does not let you delay Medicare enrollment without penalty. Once you're Medicare-eligible, marketplace plans treat you differently.

What happens at 65 on a marketplace plan
  • You lose eligibility for premium tax credits once you become eligible for Medicare
  • Keeping a marketplace plan past Medicare eligibility means you're paying full price with no subsidy
  • A marketplace plan is not employer coverage, so it does not give you a Part B Special Enrollment Period — this is the part that catches people out
  • For Part D, check the notice: some marketplace drug coverage is creditable and some is not, and only the plan can tell you which
  • Delay enrolling in Medicare while on a marketplace plan and you can face a permanent Part B late enrollment penalty — marketplace coverage does not protect you the way employer coverage does. A Part D penalty depends on whether that plan's drug coverage was creditable
What to do
  • Enroll in Medicare during your Initial Enrollment Period (the 7-month window around your 65th birthday)
  • You can cancel your marketplace plan when Medicare begins — it won't overlap
Quick reference
Can I delay Medicare?
✅ Yes — delay is allowed

Active employer coverage (yours or your spouse's) from an employer with 20+ employees. Part A is still usually worth enrolling — it's premium-free and coordinates with your group plan.

❌ No — enroll when you turn 65

COBRA, retiree coverage, marketplace plans, VA coverage alone, and most individual health plans. Missing your window triggers permanent penalties on both Part B and Part D, based on how long you delayed.

The Part B late enrollment penalty

For every 12-month period you delayed Part B enrollment without qualifying coverage, your Part B premium increases permanently. The longer you delay, the higher the increase — and it compounds with each additional year. This is not a one-time fee.

Not sure if your coverage qualifies?

Bring your coverage details to a PharmSurance advisor and we'll tell you exactly whether you can delay, when your deadline is, and what to do next. At no cost to you.

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