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A Client’s Part D Penalty Appeal Journey

Today’s video specifically relates to those who transition to Medicare through a Special Enrollment Period (SEP), Americans who work beyond age 65 and have active group coverage, and those who didn’t elect to enroll in a Part D Plan when they were first eligible. It might be of interest to many more Americans, however, since we are reporting on a government initiative to ensure that those who should pay Part D enrollment penalties pay them. We’ve been working with clients on Part D enrollment for many years and just recently learned about this initiative.

Our clients were transitioning to Medicare Part D through a Special Enrollment Period and had creditable drug coverage through employment. When using a Special Enrollment for Part D enrollment, everyone gets a letter from their Plan stating “you may owe a penalty” but if you don’t believe you do, one can return an enclosed form indicating your source of creditable coverage.

We’ve always found the form to be a bit annoying for those transitioning to Medicare through a SEP because documentation is required from the former employer(s) to enroll in Part B of Medicare. Social Security has that information as should the Medicare Benefits Coordination and Recovery Center. Our clients returned the form but within four weeks received notice from C2C Innovative Solutions, Inc., a government contractor, that they would have to supply additional information to prove their creditable coverage. We suggested they supply former ID cards and/or print screens from their former insurance portal if they still have access to it and the portal shows coverage effective dates.

This seems to be a hassle for those who worked beyond age 65 and actually saved the government money by not going on government programs. But we suspect that people who should owe a penalty have returned the form to their new Part D plan with misinformation and, hence, the government is working harder to identify those who should pay penalties and those who should not.

The takeaway here is that if you are working beyond age 65, don’t be in a rush to throw out ID cards or the signed CMS-L564 form you used to get on Part B. You may need them.