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Medicare for Veteran's.

I have been going exclusively to the VA. What should I sign up for? Do I really need the alphabet of medicare? Will parts of the medicare packages effect my VA coverage? I am a disabled veteran for hearing and have been receiving 100% of my medical services through the VA. What won't the VA cover if I do not sign up for medicare other than part A?

Thank you,

John

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@JohnS417386 some of this reply will overlap the reply by @GailL1 and some will enhance what she posted. Put the two together and you should have a good picture of the way Medicare and VA benefits work.

 

 

If you have or can get both Medicare and Veterans’ benefits, you can get treatment under either program. Generally, Medicare and VA can’t pay for the same service or items. Medicare pays for Medicare-covered services or items. Veterans’ Affairs pays for VA-authorized services or items.

When you get health care, you must choose which benefits to use each time you see a doctor or get health care.

 

Note
To get the U.S. Department of Veterans Affairs (VA) to pay for services, you must go to a VA facility or have the VA authorize services in a non-VA facility.

 

If the VA authorizes services in a non-VA hospital, but didn’t authorize all of the services you get during your hospital stay, then Medicare may pay for the Medicare-covered services the VA didn’t authorize.

 

For active-duty military enrolled in Medicare, TRICARE pays for Medicare-covered services or items, and Medicare pays second

 

For inactive-duty military, Medicare pays first for Medicare-covered services and TRICARE may pay second.

 

TRICARE pays first for services or items from a military hospital or any other federal provider

https://www.medicare.gov/supplements-other-insurance/how-medicare-works-with-other-insurance

 

In the FWIW department, I helped a Vet secure coverage earlier today. He is turning 65, has A & B and has used the VA for a dozen+ years for primary and specialty care as well as Rx.

 

Due to COVID most of his VA "appointments" are virtual and he wants the ability to see providers in person, in the private sector in lieu of using the VA teleconference system. He has a number of health issues, compounded even more by a recent stroke. Virtual appointments are not his friend.

 

He selected a Medicare supplement plan which, in conjunction with original Medicare, allow him unfettered access to health care. No networks, no referrals, no pre-authorization.

 

The supplement plan limits his OOP to the Part B deductible.

 

He also opted for a low premium ($7) PDP so he can use a retail pharmacy when needed. Most of his med's (including insulin) are SHIPPED to him by the VA clinic. VA filled Rx has very low copay's, especially for insulin.

 

He isn't my only VA/Medicare client, just the most recent one, and his situation is not unique.

 

 

One more thing . . .

 

Medicare A or B IS creditable coverage however the following are NOT creditable if you are applying for Part B outside of your IEP.

 

 

Examples of Coverage that is NOT Creditable Under Medicare
TRICARE
Veterans Benefits
COBRA
CHAMPVA
Retiree plans
FEHB

 

One curious side note, while COBRA is not creditable coverage when applying for Part B it IS considered creditable if you are applying for Part D.


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Whoever said that DETAILS weren't IMPORTANT !!!

Thanks for the added info - I will file it in my brain under VA/Medicare and other stuff

It's Always Something . . . . Roseanna Roseannadanna
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The VA does encourage you to sign up for Medicare - Part A (premium free for most people), Part B can also be also be advantageous as well as Part D. (both will have premiums unless you have very low income) 

The VA healthcare system does not bill Medicare for anything.  But having your Medicare coverage can open other medical doors to you if need be -

 

Reasons:

  • We don’t know if Congress will provide enough funding in future years for us to provide care for all Veterans who are signed up for VA health care. If you’re in one of the lower priority groups, you could lose your VA health care benefits in the future.
  • Having Medicare means you’re covered if you need to go to a non-VA hospital or doctor—so you have more options to choose from.
  • If you delay signing up for Medicare Part B (coverage for doctors and outpatient services) and then need to sign up later because you lose your VA health care benefits or need more choice in care options, you’ll pay a penalty. This penalty gets bigger each year you delay signing up—and you’ll pay it every year for the rest of your life.
  • If you sign up for Medicare Part D (coverage for prescription drugs), you’ll be able to use it to get medicine from non-VA doctors and fill your prescriptions at your local pharmacy instead of through the VA mail-order service. There’s no penalty for delaying Medicare Part D.

You will need to choose which benefits to use each time you receive care.

 

To use VA benefits, you’ll need to get care at a VA medical center or other VA location. We’ll also cover your care if we pre-authorize you (meaning we give you permission ahead of time) to get services in a non-VA hospital or other care setting. Keep in mind that you may need to pay a VA copayment for non-service-connected care.

 

If you go to a non-VA (or VA authorized) care facility, Medicare may pay for other services you may need during your stay. Or, if we only authorize some services in a non-VA location, then Medicare may pay for other services you may need during your stay. Check your Medicare plan, so you know which care locations and services you’re covered for.

 

VA Health Care and Other Insurance 

It's Always Something . . . . Roseanna Roseannadanna
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You know what I don't get?  The ACA considers VA Healthcare benefits as creditable coverage; but, Medicare Part B does not.  VA Healthcare is creditable coverage for Medicare Part D.  What this means for the Veteran enrolled in VA Healthcare, if they don't sign up for a Medicare Part B during that initial seven month enrollment period, the Veteran could incur a 10% penalty and that penalty can compound 10% for ever year delay.  What if there were no penalty for Veterans enrolled in VA Healthcare?  Let's examine the arguments for having Medicare other than the penalty.  If I had group health insurance at 65, I wouldn't incur that penalty for what is it up to 8 months after leaving the job.  If Congress suspended funding for the VA Healthcare program, why couldn't I be allowed to sign up for Medicare Part B.  Thanks to the Mission Act, I can go to a non-VA facility if there doctor can't see me in a 20 day period.  I can go to urgent care without approval or the ER in an emergency, I just need to let the VA know.  Last year, I got my flu shot at a local non-va pharmacy.  If I don't use the VA pharmacy, I can pay a small fee to get my prescriptions from select non-VA pharmacy, approved by the VA.  More to the point, there are no Monthly premiums, out of pocket maximums before coverage kicks in 100%, or donut holes like with an Medicare Advantage Plan that include prescription drugs.  And if someone had rriginal Medicare A, B, D, supplemental, monthly costs add up.  I've written my congressman.  Would AARP advocate for such a change to Medicare rules to consider VA Healthcare creditable coverage?

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@MarkL413231 

Simple answer - Medicare Part B covers cost for physician services, outpatient hospital care, and home health care that Part A does not pay for.  It also covers:  physical, speech, and occupational therapy, second opinions, certain drugs administered by a doctor, and some durable medical equipment among other things.  Depending upon the type of Medicare one picks, it is covered the same way.

 

Because of the way the VA healthcare system works in who's covered and how, where the coverage takes place including the community care option, it is NOT considered credible coverage by Medicare.  The VA system can prioritize who gets what, for how much and where.

 

Not this way in the VA prescription drug coverage - it is not prioritized - thus the VA prescription drug coverage is credible coverage for Medicare.

 

Because Medicare Part B is a beneficiary premium based funded program - A separate Medicare SMI TRUST FUND - the whole part works when everybody eligible pays premiums or if one is late signing up - the premium + the forever penalty to catch up on what one may owe the program in back pay, so to speak.

Premiums from beneficiaries cover about 25% of the Part B program - the government out of the general fund covers about 75% of the cost of the program.  

Of course, considering the SS "hold-harmless" clause and the (if applicable) annual COLA.

 

By using your rationale

Why should a Veteran ever have to pay into the Medicare Part A system via payroll taxes while working in their younger years?

Or why should an employer even offer Veterans coverage if they can sign up for the VA Healthcare system?

The VA system isn’t just for the old – it is for any person that qualifies via their service designation and priority level.

But it can change because it is a program that is dependent on Congressional budgeting and in that regard - the VA has to have some options for prioritizing care cost by specific groups - groups that are based on need and income - and thus associated cost for certain services, and now where that service may be provided under some conditions.

 

You don't have to sign up for Medicare Part B if you are enrolled in the VA health care system - you can just take your chances.  But it is for your benefit, regardless of the Mission Act including the community care provisions.  By taking Medicare Part B when 1st eligible, the Veteran can expand their options of care especially with their choice of providers and coverage especially for those non-service connected health concerns.  Then the Veteran can pick and chose the benefits (Medicare or the VA) that are the best for them by using whichever coverage is the best for their care at the time.

 

Just like any other insurance, one needs to pick the plan that is best for themselves and their healthcare needs. 

 

Watch using those outside urgent cares or any other allowable care under the VA system - they have to be within their network of outside providers.

VA Community Care  

 

Yes, Walgreens, I believe is a provider of VA community care like immunizations.

 

If you are on maintenance meds which are covered generically under the VA formulary  - try the VA Meds-by-Mail - FREE.

 

 

It's Always Something . . . . Roseanna Roseannadanna
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Thank you for your response.  There is no question, if a Veteran can financially afford it, they should sign up for a Medicare Part B.  The way the current law is written, if they don’t sign up when it comes time, they will be penalized. Periodically, the VA does an analysis called the VA Survey of Veterans Enrollees’ Health and Use of Health Care.  As you might realize, there are a significant portion of Veterans enrolled in VA Healthcare due to limited financial resources.  For some Veterans, Medicare is a luxury they can’t afford, others struggle financially paying both Medicare and their other expenses.

 

In your response to me you mention that VA Healthcare is not just for elderly, which is true, one qualifier is you have to have prior Military Service.  There is a little inconsistency here, why does the Affordable Care Act consider VA Healthcare creditable coverage and Medicare part B doesn’t?  And I would argue that even the lowest covered priority group has as good or better coverage than offered by a Medicare Advantage Plan.  As far as dental and vision go, a Veteran can find separate plans for a lot less than what they pay in a Medicare Part B premium.

 

A Veteran contributing to a Medicare Part A does make sense should they ever lose their benefits through the VA.  Employers have signup periods for health insurance and employees have the right to opt out of the company’s health plan.  No penalties to opt back in later.

 

You cite limited non-VA facilities; I would submit a Medicare Advantage Plan does that as well.  Using the VA locator, you can look up a non-VA urgent care facility for a given area, with an HMO you are restricted geographically, with a PPO you are either in network or out of network.  Veterans have a primary care doctor with the VA, and if the VA is unable to see the veteran within 20 days, they can be deferred to a non-VA facility.  As far as Pharmacy locations go, it’s not just Walgreens, it all the major pharmacy’s, CVC, Kroger, Safeway, Rite Aid, Bi-mart and a lot of the smaller pharmacy’s as well.

 

As far as the mechanic behind how Medicare works, I’m not clear your message here.  Are you saying if the government lost the premiums or penalties paid by Veterans that this could cause the demise of Medicare Part B as we know it?  Are you assuming that all Veterans would choose not to sign up for Medicare Part B if they had a choice?  Isn’t it Medicare Part A trust funds that are expected to run out by 2026?  You might want to look at the report @ va,gov, Veterans enrolled in VA Healthcare to get a little more insight here.  I don’t see any real obstacles to changing the way the law is written now to categorize VA Health care as creditable coverage as the ACA does now.

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Depending upon their income, some veterans may not even have to pay their Part B premiums – Medicare or states would subsidize it.

Medicare.gov –  Medicare Savings Programs | Medicare

 

You keep equating Medicare with Medicare Advantage – there is also Traditional Medicare.   In Traditional Medicare (some people call it Original Medicare) – there is no dental, vision or hearing currently – so use Traditional Medicare and the VA for any approved dental, vision or hearing.

 

VAHC hospital coverage isn’t considered credible coverage for Medicare Part A either but since most people don’t pay a premium for Part A we don’t hear about that too much.  But if one cannot get Premium free or low cost Part A depending upon how much they worked and paid onto the system, if they are an eligible Veteran they can get VAHC benefits. 

 

An eligible Veteran doesn’t have to have Medicare at all – they can opt to just go VA.  But there will be a penalty, for Part B or even Part A if they haven’t earned it during their working years and want to later enroll.  

 

Again – forget Medicare Advantage – the best would be to choose Traditional Medicare – get Parts A & B, use the VA for Part D (Meds by Mail, if you can – FREE)  as well as dental, vision, hearing – by going this route – you open up the full range of Medicare providers that accept assignment.  Forget networks like in MA or even the VA community care. 

Medicare.gov –  Find Healthcare Providers: Compare Care Near You | Medicare

 

Use the benefits in either program to compliment the other program.  Then the only concern that you have is to know which benefit you are using and present the correct card cause they don’t work together.

 

You asked:  Are you saying if the government lost the premiums or penalties paid by Veterans that this could cause the demise of Medicare Part B as we know it?

No, but because Part B is a closed program where beneficiary premiums (25% of the cost of Part B) pay the program benefit along with the government's (75% of the program), then someone not participating in Part B when they are eligible, raises the premium cost for all the other beneficiaries who are paying.

Part B is the SMI.

 

From the SS and Medicare Trust Fund Report (Summary) 2020:

The Supplemental Medical Insurance (SMI) Trust Fund has two accounts: Part B, which pays for physician and outpatient services, and Part D, which covers prescription drug benefits. SMI is adequately financed into the indefinite future because current law provides financing from general revenues and beneficiary premiums each year to meet the next year’s expected costs. Due to these funding provisions, the rapid growth of SMI costs will place steadily increasing demands on both taxpayers and beneficiaries.

 

Medicare.gov – Part B Cost 2021 Part B costs | Medicare

 

You asked:  Are you assuming that all Veterans would choose not to sign up for Medicare Part B if they had a choice? 

No, because it is a good idea if they do because it opens much further medical options for them - in providers, in medical access places and in some covered services.  In fact, those veteran with (Traditional) Medicare coverage – both Part A and Part B – don’t have to worry about any VA Mission Act or community care program – they can just use their Medicare benefit in place of their VAHC. – Just give the Medicare card instead of the VA.

 

Next, is the where to get care question - it becomes a $$$$ thing.  For the most part in Traditional Medicare where they pay 80% of the Medicare approved amount - this, for most things, is pretty cheap.  If you don't want to buy a Medigap plan (which works to pay some (most)  cost that Medicare doesn't pay.   It also works with the VA too as a "other health insurance" - see the important VA link at the bottom of my post - it says " We [VA] don’t bill Medicare or Medicaid, but we may bill Medicare supplemental health insurance for covered services.  I think there may some terminology differences here - since Medigap & Medicare Advantage are often times referred to as Medicare supplemental health plans.  They aren't - Medicare Advantage and Traditional (or Original) are just different ways that one can get their Medicare coverage - it is an option .  Anyway - we have some (or a) Medicare experts here - I will ask them to clear this up cause I don't know.

 

So the Medicare veteran would have to pay the remaining 20% of the already drastically reduced cost - if that doesn't work or if the care is gonna be real expensive care - like cancer treatment - then since the veteran has both coverages, they can just switch to the VAHC benefit.

 

You asked:  why does the Affordable Care Act consider VA Healthcare creditable coverage and Medicare part B doesn’t?  

Again because MEDICARE is a “paying your $$$ dues” type of program that has specific funding mechanisms that comes from the beneficiaries one way or another.  Part A is by payroll taxes paid during working years by employer and employee.  Work long enough and you get Part A Free when eligible for Medicare – IF you don’t work long enough, there is a hefty premium to pay for Medicare Part A.  Don’t pay premiums for Part B when 1st eligible without credible coverage, you pay the [forever] premium penalty as a sort of pay back.

The VAHC system for things that Part B covers is NOT credible coverage because it has too many selective loopholes in coverage (who gets what, when, where, how) as compared to CERTAIN private employer group coverage.  That’s right “certain” ones – the specific other (group) health insurance has to be approved by Medicare.  The VA is not approved

Medicare and VA do NOT work together at all – each is separate from services and money – public not private.   Each may work with private insurance but not between each other. 

Credible coverage means a health insurance that can take the place of Part B.  To further this – it means that the coverage is expected to be and pay on average as much as the standard Medicare benefit.

The VAHC prescription drug coverage is credible coverage because it can take the place of Medicare Part D.

The VAHC system is NOT considered Health Insurance – it is considered a benefit of eligible service to the Country.

 

Some links -

VA Health Care And Other Insurance | Veterans Affairs

ABOVE IS EXTREMELY IMPORTANT ⬆️  especially the part entitled:

More about how VA health care works with Medicare and other insurance

Do I Need Medicare if I Have Veterans Benefits? | MedicareFAQ

 

AARP: I am a veteran with health care coverage from the VA system. Do I need Medicare as well? 

 

If I have given you too much info that you already knew - sorry.  But if I have given you something new - then check it out.  Having the availablilty of both system really works to the (most) veterans advantage.  I just think if you ever want to use Medicare for anything - even Part A you are gonna find that not having Part B is not really gonna work too well logistically,  

 

It's Always Something . . . . Roseanna Roseannadanna
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You should enroll in Part A since it's premium-free and will allow you to get coverage at a non-VA hospital. Part B is not considered creditable coverage, so the VA does recommend you enroll so you're not penalized in the future and again, can get coverage at a non-VA doctor. This article breaks it down.

Regular Contributor

Oh no you're right, I will definitely signup for a Medicare Part A.  My lengthy discertation is more about the Veterans that can't afford to signup for a Medicare Part B and reasons why I think that the law should be changed to consider VA Healthcare creditable coverage for Medicare Part B.  If people want to see a change, they can do what I did and write their congressional representatives for their state and district.  

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@MarkL413231 

 

“My lengthy dissertation is more about the Veterans that can't afford to signup for a Medicare Part B…” @MarkL413231 

 

I totally understand your point about VA healthcare coverage not being considered creditable coverage for Medicare part B.

 

But as far as needing help with Medicare premiums there are at least 4 or 5 programs available that I’m aware of for veterans and nonveterans to get assistance in paying Medicare premiums.

 

Every state has their own established Medicare “extra help” program with income limits and qualifications that vary from state to state.

 

Every state has a Senior Health Insurance Information Program (SHIIP). It’s funded by congress and free to use.  Usually, they are part of your states Department of Insurance. They are unbiased and do not sell you insurance. SHIIP employees and volunteers specialize in Medicare issues and can answer most all your questions and assist you in applying for extra help with Medicare. They also employ veterans’ healthcare specialists.
https://www.shiphelp.org/#.html

 

An individual can contact a number of places to see if they qualify for Medicare “extra help”.

 

Regular Contributor

Yes, there are programs out there for Veterans and others, and as the need dictates, IIf in need, Veterans should reach out to VA, social services, to navigate these programs; but, just know, a Veteran must be at or near poverty to qualify.  Extra Help paying for drugs, income less than $ pr19,140 for a single person; in my state, QMB program 100% of poverty level, SLMB from 100% to 120% of poverty level; qi program limited enrollment; qdwi disabled and low income from 120% to 135% of poverty level.  What would be alot more helpful is if there was one simple Medicare rule change, and that is to also consider VA Healthcare benefits to be creditable coverage.  Give Veterans a choice whether or not to enroll or continue on with a Medicare Part B.  Yes, VA funding may not be forever for some groups; but, it funding were curtailed, then the Veteran can choose whether or not to apply for Medicare.  

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H.R. 480 Medicare Economic Security Act was proposed in January of this year, it iss intended to limit the Medicare Part B penalties and to broaden the definition of what is considered to be creditable coverage to include those who have COBRA benefits and who are enrolled in VA Healthcare.  Very few bills make their way through the legislature; but, Veterans issues are typically bipartisan.  You could help this legislation by writing to your district rep in the House of Representatives as well as your Congressional representatives in the Senate.  Remember, :the squeaky wheel gets the grease.

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@MarkL413231 

RE:  H.R. 480 - Medicare Economic Security Act - 

 

Maybe everybody should be able to sign up for Medicare Part B when they need it and not before, penalty free, of course.   How many other insurance products can you think of that let's one buy coverage only when they need it?

 

COBRA coverage, if one has them when they turn 65 and become Medicare eligible, is often cancelled by the insurer so the Medicare beneficiary has to go on Medicare Part B. 

Medicare.gov - COBRA: 7 important facts 

 

Retiree Insurance works with Medicare.  Retiree Insurance requires that the Medicare eligible beneficiary have both Medicare Part A and Part B to get the full retiree coverage.

Medicare.gov - Retiree insurance 

 

Same thing with VA health benefits and Medicare - when one becomes eligible for Medicare - for full Medicare coverage, one needs both Part A and Part B to have full coverage for Medicare in case the Veteran decides to use Medicare instead of the VA Health System.  Having only Medicare Part A and not Part B at the time the Veteran needs or wants to use it would leave the Veteran exposed to medical cost.  Then, of course, there is the logistics - government take time to sign one up for the program and Medical cost are sometimes not a planned type of event.

 

I just don't think it will work specifically because insurance of any type is not designed to pick up only when the need arises - insurance of any type is a compilation of everybody's premiums paid into a pot to create coverage dollars - (and profits if private coverage).

 

Maybe the main problem is that Medicare and the VA health system don't overlap - in essence, the Veteran who has both has to choose which they use at any given time.

 

CHAMPVA is different - it works with Medicare - Part A & Part B - use a Medicare doctor - the claim goes through Medicare and then the remainder is sent to CHAMPVA - very similar to having a Medigap plan.

 

It's Always Something . . . . Roseanna Roseannadanna
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Openning this up to everybody probably would likely put the integrity of the whole Medicare program at risk; but, not if this was limited to Veterans and COBRA recipients.  At most, we're talking about 4.5 million Veterans, and it's highly unlikely that most of those Veterans would forgo a Medicare Part A and B.  As for COBRA, I don't know how may people we are talking about; but, from my own personal experience, having Medicare Part A, B & a United Health Care Medicare Supplemental Plan  G is likely a less expensive option.  As for Dental plan, I have one that pays up to $2000 in benefits per year, costs less than $43 a month.  Now I have Vision through VA; but, if I didn't, their are places like Costco where the you can get an exam and glasses for less than $300.

 

Thinking about insurances that allow you to signup when you need it with no penalties for pre-Existing conditions would be a program like the Affordable Care Act.  Veterans doesn't seem to care about pre-existing conditions either.  If I'm not mistaken, I don't think a Medicare Advantage Plan slook at pre-existing conditions either.  I think it could work because doesn't HR 480 would include VA Healthcare and COBRA as creditable coverage so it's no different that someone who had group health insurance with an employer at age 65 and waiting until they no longer had that coverage to signup for Medicare.

 

But you know, you are right about one thing, VA and Medicare are two separate systems.  Any Veteran who opts out of Medicare Part B, by choice or by necessity, does limit there options on care.  When I was on the ACA plan, I had to choose from various HMO'sand PPO's.  Not all the plans were the same, you could only go to certain facilities within your community.  With a PPO, you could travel outside your community have have coverage, you paid in-network or out of net-work fees.  I'm sure a Medicare Advantage Plan is similar.  But to my point, the Veteran has to be just as studios about there plan.  Knowing where the nearest VA facility or preapproved Non-VA Urgent Care is relative to wear they live or anywhere they are going in the country,  The highest fee a Veteran pays to go to an urgent care is $30, a prescription outside the VA system is less than that, if the Veteran can't wait for the VA Pharmacy, and if the Veteran has to visit a non-VA ER, he just has to notify the VA within 3 days of surface.  

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Proposed H.R. 480  Penalty Change:

Now let’s look at the Part B late penalty change in proposed H.R. 480 –

 

Currently it is 10% for each 12-month period you could've had Part B, but didn't sign up. In most cases, you'll have to pay this penalty each time you pay your premiums, for as long as you have Part B. And, the penalty increases the longer you go without Part B coverage.

 

EXAMPLE:  a Part B regular [standard] premium of $ 150.00 per month but the beneficiary was (2) years late in signing up means a penalty of $ 30.00 per month – so a total premium of $ 180.00 per month (for that year).  The penalty remains forever as the premiums increase, year after year.

$ 150.00 X 10% = $ 15.00 X 2-years = $ 30.00 per month penalty

 

Proposed H.R. 480 want to change this to:  a late enrollment penalty of 15% of monthly premiums and applies the penalty for a period equal to twice the number of months in each 12-month period during which the individual was not enrolled.

 

EXAMPLE:   a Part B regular [standard] premium of $ 150.00 per month but the beneficiary was (2) years late in signing up means a penalty of $ 22.50 per month.

$ 150.00 X 15% = $ 22.50    

 

– so a total premium of $ 172.50 per month (for that year) then remains for a period equal to twice the number of months in each 12-month period during which the individual was not enrolled.  The penalty remains for the stated period (see next paragraph)as the premiums increase, year after year.

 

The way I understand this – the $ 22.50 penalty would last for (4) years (48 months) since the person was 2-years ( 24 months) late in signing up and the proposed legislation says “twice” the number of months.

Is my math right?

 

Still pays to sign up when 1st eligible -

 

It's Always Something . . . . Roseanna Roseannadanna
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Your math is right; but,the proposed excludes from paying those penalties.

 

"To amend title XVIII of the Social Security Act to limit the penalty for late enrollment under part B of the Medicare Program to 15 percent and twice the period of no enrollment, and to exclude periods of COBRA, retiree, and VA coverage from such late enrollment penalty."

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