The fastest money in retiree benefits is sitting in your own eligibility file.
Some retirees on your plan are already entitled to Medicare, and their claims are still paid as if they were not. Nothing has to be applied for to fix that, because the entitlement already exists. We reconcile Medicare entitlement against the eligibility file so the plan pays in the order the rules already set.
Entitlement arrives through Social Security. The plan hears about it from nobody.
Medicare entitlement is recorded by the federal government, and the eligibility file only knows what someone tells it.
Entitlement Through Disability
A retiree under 65 becomes entitled to Medicare after 24 months of Social Security disability benefits. The retiree rarely thinks to tell the plan, so the plan keeps paying first for someone Medicare should be paying for. Disability-based Medicare entitlement is easy for a plan to miss.
Turning 65 Without a Flag
When the eligibility file does not trigger a change at 65, the plan never moves to secondary. The error persists quietly, because nobody receives a bill that looks wrong. Age 65 flags keep Medicare coordination accurate. Check every file. Running the check at each renewal and after any eligibility system change catches gaps before they build up.
Spouses and Dependents
A covered spouse’s entitlement is as easy to miss as the retiree’s. We check every covered person, not only the retiree, because the coordination rule applies to each of them separately. Checking every covered person makes reconciliation complete. Each person counts separately.
Part A Without Part B
Some people have premium-free Part A and never took Part B. The plan terms decide how their claims are paid, which is why reconciliation also shows who needs an enrollment conversation. Reconciliation shows who needs a Part B enrollment conversation.
Match the file to entitlement, then fix the payment order going forward.
The work is data first and conversation second, and nothing changes until the retiree has been told.
Matching Entitlement
We compare the eligibility file with the Medicare entitlement information available to the plan, including what the plan’s own Medicare reporting returns. Each match is confirmed person by person, because a wrong flag creates a claim problem of its own.
Correcting the Payment Order
Once entitlement is confirmed, coordination is updated so Medicare pays first from then on. We manage the vendors behind the change, so providers are told where to bill and nobody is left in between. Correcting payment order protects the plan going forward.
Looking Back
Claims already paid as primary may be recoverable from providers, who can then bill Medicare within Medicare’s own filing limits. We size what is realistic to recover before anyone asks for it, which is why speed matters. Prompt reconciliation maximizes recoverable claims.
The fix changes who pays the provider. It should not surprise the retiree.
A retiree who suddenly sees Medicare on an explanation of benefits needs to know why before the first one arrives.
Telling Them First
We explain the change in plain terms, including that their providers will now bill Medicare first. A retiree who hears it from us does not first hear it from a confused billing office. Early communication protects retiree trust. Tell them before billing changes.
Part B Enrollment
Where someone entitled to Part A has not taken Part B, we explain the enrollment periods and any penalty exposure, so the decision is theirs and is made with the facts. Clear guidance helps retirees decide on Part B. The decision is theirs.
Their Own Costs
Medicare paying first changes each retiree’s out-of-pocket picture, and the direction depends on the plan terms and on whether Part B premiums are reimbursed. We check it for each person, because the work is only right if it is right for them.
What plan sponsors ask about entitlement reconciliation.
Do we need the retiree’s permission?
The entitlement exists whether or not anyone acts on it, and the plan’s coordination terms apply either way. We still tell every affected retiree before anything changes, and counsel reviews the communication. Clear communication keeps entitlement reconciliation smooth. Retirees hear first.
How soon does it change anything?
The payment order changes as soon as coordination is updated. What can be recovered on past claims depends on service dates and provider filing limits, which is why the reconciliation should come first. Starting reconciliation early protects plan recoveries. Start early.
Is this only for large retiree groups?
No. A small retiree group with a few people already entitled to Medicare can carry large claims. The work scales with the file, not with the size of the employer. Entitlement reconciliation pays off for small retiree groups, where one misrouted claim is a large share of plan spend.
Where the Rules Come From.
The laws and rules named on this page link to the statute or regulation they come from. This is general information, not legal or tax advice, and rules change, so check the current text.
COBRA Continuation Coverage (29 U.S.C. 1161)
Requires many group health plans to offer temporary continuation coverage after a qualifying event.
Send us your renewal.
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The renewal letter
Your current plan summary
Contribution split by tier
Enrolled counts by tier
Four documents — two more if your group is 50 or more. Nothing else; every extra one is a reason to postpone.
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