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Specialty Advisory

An employee turning sixty-five needs a decision made correctly, not a pamphlet.

The choice between staying on the employer plan, moving to Medicare, or coordinating both has real financial consequences and enrollment windows that do not reopen. Most employees are left to work it out alone, and the ones who get it wrong find out through a penalty that follows them for life.

Get Your Sixty-Five-Year-Olds Real Guidance

Who Pays First

Twenty employees decides which plan is primary.

This is the rule that governs the whole conversation, and it is size-dependent in a way that surprises smaller employers.

Twenty or More Employees

The group plan generally pays first for an active employee aged sixty-five or over, and Medicare pays second. An employee can reasonably keep the group plan and delay Part B without penalty. The count looks across the employer’s workforce in the current or prior year, not per plan. Employees with an HSA need extra care: enrolling in any part of Medicare ends HSA contributions, and Part A coverage can start retroactively.

Fewer than Twenty

Medicare generally pays first. An employee who declines Part B while relying on the group plan can find their claims substantially unpaid — the single most damaging misunderstanding in this area. The group plan is usually written to pay as if Medicare had paid first, whether or not the employee enrolled. We confirm how your carrier coordinates before anyone near sixty-five decides to skip Part B.

When Coverage Ends

Losing group coverage opens a special enrollment period for Part B. Employees regularly assume continuation coverage preserves that window in the same way active employment does, and plan accordingly. It does not work the way they expect. The window is measured from the end of active employment, not the end of COBRA, because COBRA is not coverage based on current employment. An employee who retires onto COBRA and waits can miss it.

How continuation actually works →

The Obligation You Already Have

Creditable coverage has no employer size exemption.

Of all the notice duties, this is the one most often missed entirely, because it has no headcount threshold to hide behind and it does not run off your plan year.

To Individuals, Before October 15

Every year, to Medicare-eligible individuals covered by your plan — which includes active employees, spouses and dependents, not just retirees. The date is fixed to the Medicare annual enrollment period, not to your renewal. A notice that reaches only employees misses covered spouses and dependents who are Medicare-eligible. We help check the distribution list against enrollment data so they are included.

To the Agency, Within Sixty Days

A separate disclosure to the federal agency within sixty days of the start of your plan year. Two different obligations, two different audiences, commonly confused for one. It is filed online on the agency’s disclosure form, and a new one is due when the plan’s drug coverage ends or its creditable status changes. We put it on your compliance calendar next to the individual notice.

Creditable or Not, And The Test Has Changed

Whether your drug coverage is creditable is a determination about your plan, not a formality. It changes what you must tell employees, and it changes what they should do. It is also no longer the test you may remember: the old simplified determination is not available for 2027, and the method now written into the regulation asks whether the plan is designed to pay, on average, at least seventy-three percent of participants’ prescription drug expenses. A plan that was creditable last year is not automatically creditable now.

The full notice set →

Retiree Coverage

If you offer it, run it as its own program.

Design and Funding

How the coverage is structured and paid for — a retiree-only plan, a trust, a captive, or a reimbursement design that sends retirees out to buy their own — is a decision of its own, and it is worked through on the group retiree plan page rather than settled here.

Administration That Is Separate

Billing, eligibility and communications for retirees work differently from active employees. Bolting them onto the active population is where errors accumulate. Retiree premiums are often billed to the retiree directly, eligibility ends on events such as Medicare entitlement rather than termination, and communications go to home addresses rather than through HR. We set those rules up with the carrier at the start.

One-To-One Education

Employees approaching sixty-five get a conversation about their own situation — spouse, prescriptions, providers, income — rather than a handout. It is an hour that prevents a lifetime penalty. It covers whether to take Part A and Part B now or later, how Medicare would coordinate with your plan, and what it means for an HSA. Employees leave with the dates that apply to them in writing.

Who they would be talking to →

The group retiree plan itself — pre-Medicare and post-Medicare →

Group Medicare

The subsidy is one route. A group Part D plan is the other.

An employer that covers drugs for its retirees is choosing between claiming the retiree drug subsidy and moving that coverage into a Part D plan written for its own retiree group. It is a real fork, and it is settled on your own numbers rather than on a rule of thumb.

How a Group Plan Is Different

A Part D plan offered to one sponsor’s retirees runs under waivers CMS grants specifically for employer group coverage: enrollment can be limited to Part D eligible people in your retiree plan, and the premium can be set separately. Everything CMS has not waived still applies.

What Actually Decides It

The subsidy is claimed and reconciled after the fact. A group plan changes who carries the drug spend and how it is financed. Which one comes out ahead turns on your retiree count, your drug mix and how rich the coverage is, so it is arithmetic run on your data, not a position to hold.

The Transition Is the Risk

Retirees enroll as individuals, so the move is a member-level exercise: who is eligible, who already bought a plan of their own, who needs to be walked through it by name. A design that works on paper fails when a retiree does not understand what arrived in the mail.

Where a subsidy year can still be corrected →

Common Questions

What employers ask about Medicare and retirees.

When does an employee need to decide?

Around their sixty-fifth birthday, and the right answer depends on your group size. At twenty or more employees your plan generally pays first and delaying Medicare is often reasonable. Below twenty it usually is not, and a wrong assumption creates a lifetime penalty.

What does the employer have to send?

Creditable coverage notices — to individuals before October 15 each year, and to the agency within sixty days of the plan year start. A short task on a fixed calendar, and one that is regularly missed. The disclosure to the agency is also due within 30 days after the drug plan ends or its creditable status changes.

Can we just hand people a brochure?

You can, and most employees need more than one. This is a one-to-one conversation about a decision with permanent consequences, which is why we treat it as education rather than a placement. The conversation works best a few months before the employee’s sixty-fifth birthday, when the initial enrollment window is about to open, and it includes the spouse where the spouse’s coverage depends on the decision.

Ask us one we did not answer →

Bloomfield Hills, Michigan

Medicare and Retiree Benefits Guidance in Bloomfield Hills for Employers and Their People

Employees near 65 often ask HR whether they need to sign up for Medicare. Many HR teams are not sure what to say, and a wrong answer can cost an employee money for years. Medicare and retiree benefits guidance in Bloomfield Hills helps employers give clear, correct answers.

We are an independent employee benefits consulting firm, in business since 2007. We work with employers in Bloomfield Hills, Birmingham, Troy, Oakland County and across Michigan.

Medicare & Retiree Benefits Guidance

Medicare and group health plans follow rules about which one pays first. There are also notice deadlines that employers must meet. We help you with both, and with any coverage you offer retirees.

How our Medicare and retiree benefits guidance in Bloomfield Hills works:

We explain how your group plan works with Medicare for employees who keep working past 65.
We help you send the Medicare Part D creditable coverage notice by October 15 each year. “Creditable coverage” means your drug plan is expected to pay at least as well as standard Medicare drug coverage.
We give HR simple talking points for employees near 65.
We review options for retirees, from a group retiree plan to a fixed-dollar amount.
We connect you with ERISA attorneys and CPAs through the firm when a question needs one.

Do employees have to sign up for Medicare at 65 if they still work?

Not always. For employees who are still working, the group plan generally stays primary, which means it pays first. Many people choose to delay parts of Medicare. The right answer depends on the employer’s size, the plan and whether the person has an HSA. Getting it wrong can lead to late penalties or gaps in coverage. Employers also may not push active employees onto Medicare in place of the group plan. We give HR clear guidance, so employees can make their own informed choice.

What is the Medicare Part D creditable coverage notice?

It is a yearly notice. It tells Medicare-eligible members whether your drug coverage is creditable. It must go out by October 15. People who go too long without creditable coverage may pay a penalty if they join Part D later. We put this date on your calendar and help you meet it. We help keep you ERISA compliant, too.

Common questions

Do we have to offer retiree coverage?

No. Retiree coverage is a choice. If you offer it, we help you set it up and review it each year. The main decisions are who qualifies, how much the company pays and whether the promise can change later. Writing the right to amend or end it into the plan documents keeps future options open.

Where do retirees under 65 get coverage?

They may have a group retiree plan, federal COBRA or an individual plan. Michigan has no state continuation law. COBRA applies at 20 or more employees, and under 20 there is no continuation duty. Individual plans can come with premium tax credits based on income, which can make them a practical bridge to Medicare at sixty-five.

Does the notice apply to small employers?

Yes. It applies to employers of any size that offer drug coverage to Medicare-eligible people. Size does not change the obligation, only the audience. A company with a handful of employees still owes it to any covered employee, spouse or dependent who is eligible for Medicare, including through disability.

Talk to us about Medicare and retiree benefits guidance in Bloomfield Hills

Send us your renewal or book a 30-minute call. Visit us at 41000 Woodward Avenue, Suite 350 East, Bloomfield Hills, MI 48304, or call 248.370.8853.

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Send us your renewal.

We’ll tell you whether it looks competitive, where we see opportunity, and the five questions we’d put to your carrier. No cost, and no obligation to move anything.

Start the Review 248.370.8853

What to send

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.

An independent employee benefits consulting firm. We look at the entire benefits program — cost, plan performance, risk and administration.

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Michigan41000 Woodward Avenue, Suite 350 East
Bloomfield Hills, MI 48304
248.370.8853

Colorado13540 Northgate Estates, Suite 100
Colorado Springs, CO 80921
719.425.2649

Texas16365 Park Ten Place, Suite 182
Houston, TX 77084
281.404.5670

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