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Still working at 65: do you need Part B?

If you (or your spouse) are still working and covered by that employer's group health plan, you can usually delay Part B without a penalty when the employer has 20 or more employees. If the employer has fewer than 20, Medicare generally pays first, and you'll usually want Part A and Part B when you're first eligible.

By Nick Heyse, independent licensed insurance agent (NPN 20605586) · Last reviewed October 2026

The employer-size rule

Your job-based coverageWho pays firstPart B usually
Employer with 20 or more employeesThe employer planCan be delayed without penalty
Employer with fewer than 20 employeesMedicareEnroll when first eligible
COBRA or retiree coverageMedicareEnroll — this doesn't count as current employment

The coverage has to be based on current employment — yours or your spouse's. That's the detail people miss most often with COBRA and retiree plans.

When the job coverage ends

You get a Special Enrollment Period of 8 months to sign up for Part B without a penalty, starting the month after the employment or the coverage ends, whichever comes first. Don't wait for the end of it — a gap in coverage can still happen.

Social Security will ask for two forms: CMS-40B (the Part B application) and CMS-L564, which your employer fills in to show you had coverage.

Part A, drugs and HSAs

  • Part A: most people pay no premium for it, so many take it at 65 even while working — unless they're contributing to an HSA.
  • HSA: once you have any part of Medicare you can't keep contributing, and Part A can start up to six months back. Plan the timing with your tax advisor.
  • Drug coverage: ask HR for the notice that says whether your drug coverage is "creditable." If it is, you can delay Part D without a penalty.

Your Medigap window waits for Part B

Your six-month Medigap Open Enrollment Period starts when Part B starts. Delaying Part B also delays that window, which matters in Kansas, where there's no second chance without health questions.

Check it yourself: the official sources are Medicare.gov and 1-800-MEDICARE (TTY 1-877-486-2048).

1-800-MEDICARE is available 24 hours a day, 7 days a week.

Not sure what applies to your job coverage?

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