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If I have a disability and receive Medicare benefits before age 65, can I sign up for a Medicare Part D drug plan at the same time?

Category: Medicare Enrollment Periods (IEP and AEP)
Updated: May, 25 2023

Yes.  If you are eligible for Medicare Part A and/or Medicare Part B (because you are 65 or have a disability), you are also eligible to enroll in a Medicare Part D prescription drug plan or Medicare Advantage plan that includes prescription drug coverage (PDP or MAPD).

When you become eligible for Medicare, you will have a Medicare Part D Initial Enrollment Period (IEP) during the seven (7) month period around the month when you become eligible for Medicare benefits - that is three months before the month when you become eligible - the month of Medicare eligibility - and three months after the month of eligibility.

But, no matter how early you enroll in a Medicare Part D prescription drug plan, your drug plan benefits can begin no earlier than the first day of the month of your Medicare eligibility.

A note about the late-enrollment penalty

If you decide not to join a Medicare Part D plan after the end of your IEP and then later join a Medicare Part D plan during the annual Open Enrollment Period (AEP), you may be subject to a late-enrollment penalty for each month that you are without creditable drug coverage.

Medicare before reaching 65 and your second IEP (IEP2)

If you receive Medicare benefits due to a disability, you will actually have two (2) Initial Enrollment Periods.  You will have an IEP when you first become eligible for Medicare due to your disability and then you will qualify for a second Medicare Part D initial enrollment period (IEP2) when you turn 65 and you will again have a seven month window of time to join a Medicare Part D prescription drug plan around the month when you turn 65 (three months before the month when you turn 65 plus the month you turn 65 plus three months after the month you turn 65) .

And if you choose to join a Medicare Part D plan when you turn 65 (during your IEP2), you will not be subject to any past late enrollment penalties -  even if you did not enroll in Medicare when you first became eligible due to your disability during your first IEP (please see Medicare example below).

Question:  Where can I learn more about the IEP2 and a previous late enrollment period?

See our Frequently Asked Question (FAQ):
If I receive Medicare benefits before age 65 and don't join a Medicare drug plan, will I pay a late-enrollment penalty if I decide to join a Part D plan when I turn 65? -- found at: Q1FAQ.com/203

-- and you can review the following official Medicare Part D manual information:

CHAPTER 4 Creditable Coverage Period Determinations and the Late Enrollment Penalty,

Section 10.1.3 - End of the Subsequent Part D IEP

An individual who is entitled to Medicare prior to turning age 65 (e.g., those who were entitled based on disability), will have a new or subsequent Part D IEP [Initial Enrollment Period] when they become entitled to Medicare based on age.  If an enrollee attains age 65 while enrolled in a Part D plan and has been paying an LEP [late-enrollment penalty], his/her LEP will end on the day before his/her subsequent IEP begins, which is three months prior to the month s/he attains age 65.

Example: Mrs. Brown was initially eligible for Medicare based on a disability, but never enrolled in a Part D plan. She will turn 65 on May 19 and her new (or subsequent) IEP will begin on February 1 and continue through August 30. If she enrolls in a Part D plan during this subsequent IEP, she will not be subject to an LEP.

Note: If, in this example above, Mrs. Brown was already enrolled in a Part D plan when she attained age 65, her current plan must take appropriate actions to have the LEP removed effective on the date that her IEP begins, which is February 1. See §30.4.3 for more information.

https://www.cms.gov/files/document/final-creditable-coverage-and-lep-guidance-chapter-4-revised-january-5-2018.pdf Updated: December 21, 2009 (Revised: January 5, 2018) [emphasis added]

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