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 some form of 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 (IEPs).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 on this site
Sources include:
Chapter 4 - Creditable Coverage Period Determinations and the Late Enrollment Penalty Guidance
Issued: December 21, 2009, Revised: January 5, 2018, August 5, 2024, Updated: December 21, 2009 (Revised: January 5, 2018)
[emphasis added]
Section 30.1.3 - End of the Subsequent Part D IEP
An individual who had Medicare prior to turning age 65 (e.g., based on disability or ESRD), will get another, or "subsequent" IEP [Initial Enrollment Period] when turning age 65. This subsequent IEP starts three months before turning age 65, includes the month the person turns 65, and ends 3 months after the month the individual turns age 65.
If an individual turns age 65 while enrolled in a Part D plan and has been paying a Part D LEP, their Part D LEP [late-enrollment penalty] will end on the day before their subsequent IEP begins, which is three months prior to the month that the individual turns 65. Any prior Part D enrollment gap on the individual's record (which is reported as the NUNCMO in the MARx system) will automatically be reset to "0." If an individual remains enrolled in a Part D plan or has other creditable coverage without any gaps in enrollment in the future, their NUNCMO will remain at "0."
Example:
Ms. Shervelle had Medicare based on disability and when she enrolled in her Part D plan, she had a Part D enrollment gap with a NUNMCO of six months on her record. She turned 65 on May 19, 2021. Her subsequent IEP began February 1, 2021 and ended August 31, 2021. Ms. Shervelle's six uncovered months were reset to "0" as of February 1, 2021. She was no longer charged a Part D LEP by her Part D sponsor. After a reset occurs, a Part D sponsor only counts the number of days from the end of the individual's subsequent IEP when determining a future coverage gap.
Example:
Using the example above, Ms. Shervelle disenrolled from her Part D plan, effective June 30, 2021. Later, she enrolled in a new Part D plan, and her plan coverage started January 1, 2022. Ms. Shervelle's Part D enrollment gap started September 1, 2021 (the day after her subsequent IEP ended) and ends on December 31, 2021. The Part D enrollment gap for Ms. Shervelle is four months. Ms. Shervelle's previous six-month NUNCMO, and the period that she was not enrolled in a Part D plan during her subsequent IEP, do not count in determining her enrollment gap.
An individual who had Medicare prior to turning age 65 (e.g., based on disability or ESRD), will get another, or "subsequent" IEP [Initial Enrollment Period] when turning age 65. This subsequent IEP starts three months before turning age 65, includes the month the person turns 65, and ends 3 months after the month the individual turns age 65.
If an individual turns age 65 while enrolled in a Part D plan and has been paying a Part D LEP, their Part D LEP [late-enrollment penalty] will end on the day before their subsequent IEP begins, which is three months prior to the month that the individual turns 65. Any prior Part D enrollment gap on the individual's record (which is reported as the NUNCMO in the MARx system) will automatically be reset to "0." If an individual remains enrolled in a Part D plan or has other creditable coverage without any gaps in enrollment in the future, their NUNCMO will remain at "0."
Example:
Ms. Shervelle had Medicare based on disability and when she enrolled in her Part D plan, she had a Part D enrollment gap with a NUNMCO of six months on her record. She turned 65 on May 19, 2021. Her subsequent IEP began February 1, 2021 and ended August 31, 2021. Ms. Shervelle's six uncovered months were reset to "0" as of February 1, 2021. She was no longer charged a Part D LEP by her Part D sponsor. After a reset occurs, a Part D sponsor only counts the number of days from the end of the individual's subsequent IEP when determining a future coverage gap.
Example:
Using the example above, Ms. Shervelle disenrolled from her Part D plan, effective June 30, 2021. Later, she enrolled in a new Part D plan, and her plan coverage started January 1, 2022. Ms. Shervelle's Part D enrollment gap started September 1, 2021 (the day after her subsequent IEP ended) and ends on December 31, 2021. The Part D enrollment gap for Ms. Shervelle is four months. Ms. Shervelle's previous six-month NUNCMO, and the period that she was not enrolled in a Part D plan during her subsequent IEP, do not count in determining her enrollment gap.