Medicare Part B COBRA coordination

Full Title:
Medicare Enrollment Protection Act of 2025

Summary#

This bill creates a special enrollment period (SEP) that lets people on COBRA continuation coverage sign up for Medicare Part B while they still have COBRA or within three months after COBRA ends. It also says months spent on COBRA can count toward avoiding a Part B late‑enrollment premium increase, and it stops COBRA plans from cutting or ending benefits just because someone is eligible for Part B but has not yet enrolled. The bill requires updated COBRA notices that explain how Medicare pays when other coverage exists.

  • Main change: People enrolled in COBRA (starting Jan 1, 2026 or later) get a one‑time SEP that covers each month they are on COBRA and the three months after their last COBRA month.
  • Premium rule: Months on COBRA can be shown to avoid an increase in the Part B premium for late enrollment.
  • Coordination rule: COBRA plans, federal continuation plans, and similar state plans cannot reduce or end benefits just because someone is eligible for Part B but not enrolled; they must treat the person as if they were not eligible for Part B.
  • Enrollment start date: If someone enrolls in Part B during this SEP, their Part B coverage begins the first day of the month after they enroll.
  • Notices: The Labor Department must update COBRA written notices by Jan 1, 2026 to explain Medicare secondary payer rules and how they apply to COBRA.

What it means for you#

  • People on COBRA who turn eligible for Medicare Part B (for example, at age 65 or due to disability): You can use a special enrollment period one time in your life to sign up for Part B during any month you have COBRA or within three months after COBRA ends. If you enroll in that window, your Part B coverage starts the first day of the month after you enroll.
  • People worried about the Part B late‑enrollment penalty: If you can prove you were enrolled in COBRA, those months can be counted so they do not increase your Part B premium under the late‑enrollment rules.
  • People on COBRA who are eligible but have not enrolled in Part B: Your COBRA plan cannot reduce or stop benefits just because you are eligible for Part B but have not yet enrolled. COBRA plans still may stop or reduce benefits if you actually enroll in Part B.
  • Employers, plan administrators, insurers, and state continuation plans: You must follow the new coordination rules that prevent cutting COBRA benefits solely for Medicare Part B eligibility. You will also need to update or follow revised COBRA notices from the Department of Labor.
  • Federal employees with continuation coverage under title 5: The bill covers their continuation coverage the same way as COBRA.

Expenses#

No publicly available information on cost estimates or a fiscal note was provided with the bill text.

  • Possible administrative costs for employers, plan administrators, and insurers to change plan rules, update materials, and handle coordination of benefits.
  • Department of Labor and Health and Human Services may have minor costs to revise and distribute required COBRA notices and guidance.
  • Potential changes in claims processing and coordination systems where COBRA plans must treat eligible-but-unenrolled Medicare beneficiaries as if they were not eligible for Part B.

Proponents' View#

  • The bill appears intended to reduce gaps in coverage and confusion for people moving from employer coverage to Medicare.
  • It could protect people from Part B premium increases by letting months on COBRA count toward the enrollment penalty rules.
  • It aims to prevent COBRA plans from terminating or reducing benefits just because someone is eligible for Medicare Part B but has not yet signed up.
  • Updated notices are meant to make the Medicare secondary payer rules clearer to people on COBRA.

Opponents' View#

  • One concern is added administrative and compliance costs for employers, insurers, and plan administrators to implement the coordination rules and update notices.
  • The requirement that COBRA treat eligible-but-unenrolled individuals as if they were not eligible for Part B could raise costs for those plans, potentially affecting premiums or plan design.
  • The bill allows the special enrollment period only once in a person’s lifetime; it is unclear how that limit will affect people with complex coverage changes.
  • It is not fully clear how these rules will interact with existing Medicare secondary payer processes or how disputes (for example, about whether someone was enrolled in COBRA during a month) will be resolved.

What is unclear: The bill text does not include a government cost estimate, nor detailed guidance on enforcement, dispute resolution, or how documentation of COBRA enrollment must be presented to Medicare.