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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? What if I decide NOT to join a Part D plan, do I pay a penalty if I decide to join a Part D plan when I turn 65?

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Question: 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? What if I decide NOT to join a Part D plan, do I pay a penalty if I decide to join a Part D plan when I turn 65?
Category: Medicare Part D Enrollment

Answer: 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.

You have a Medicare Part D initial enrollment period (or IEP) during a seven (7) month period around the time 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.  If you sign up early, Part D benefits begin on the first day of the month of your Medicare eligibility.

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, you may be subject to a late-enrollment penalty for each month that you are without creditable drug coverage.

However, if you receive Medicare benefits due to a disability, you actually receive a second Medicare Part D initial enrollment period (IEP) when you turn 65.

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.) .

If you have a disability and choose to join a Medicare Part D plan when you turn 65 (during your second IEP), 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 (please see Medicare example below).

For more information, please see:


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.

The Part D plan sponsor shall have a process in place for identifying members who are attaining age 65 or who have recently attained 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.

Section 30.4 - Reporting Adjustments to Creditable Coverage Period Determinations Previously Reported to CMS

D. Reporting Adjustments Based on Subsequent Part D IEPs

As explained in §10.1.3 of this Chapter, an individual who is eligible for Medicare prior to turning age 65, will have a new (subsequent) Part D IEP based on entitlement to Medicare due to attaining age 65. Any uncovered periods prior to the first day of their subsequent Part D IEP will not be counted towards any future number of uncovered months.


Mrs. Smith is entitled to Medicare due to disability, but did not join a Medicare prescription drug plan when she was first eligible, and has been paying a LEP based on 9 uncovered months. Mrs. Smith turns age 65 on April 3, 2008. Her last day to be assessed an LEP is December 31, 2007, the day before her second or subsequent IEP begins on January 1, 2008.

(Source: https://www.cms.gov/medicare/eligibility-and-enrollment/medicarepresdrugeligenrol/downloads/final_cy2010_medicareprescriptiondrugbenefitmanualchapter4_dec2009.pdf [emphasis added])

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Tips & Disclaimers
  • The Medicare Advantage and Medicare Part D prescription drug plan data on our site comes directly from Medicare and is subject to change.
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  • If you are enrolled in a Medicare plan with Part D prescription drug coverage, you may be eligible for financial Extra Help to assist with the payment of your prescription drug premiums and drug purchases. To see if you qualify for Extra Help, call: 1-800-MEDICARE (1-800-633-4227). TTY users should call 1-877-486-2048, 24 hours a day/ 7 days a week or consult www.medicare.gov; the Social Security Office at 1-800-772-1213 between 7 a.m. and 7 p.m., Monday through Friday. TTY users should call, 1-800-325-0778; or your state Medicaid Office.
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