Does COBRA Count as Creditable Coverage for Medicare?

Medicare Insurance for Seniors

Medicare Insurance for Seniors

When navigating health insurance options, understanding how COBRA (Consolidated Omnibus Budget Reconciliation Act) coverage interacts with Medicare is crucial. One common question is whether COBRA qualifies as creditable coverage under Medicare rules. Let’s delve into the details to clarify this important issue.

What is COBRA?

COBRA allows individuals to continue their employer-sponsored health insurance coverage after leaving employment, usually for up to 18 months, though in some cases, coverage can extend up to 36 months. This continuation is typically available if you lose your job or experience a reduction in work hours.

 Understanding Creditable Coverage

Creditable coverage refers to health insurance that is expected to pay, on average, at least as much as Medicare’s standard prescription drug coverage. This concept is particularly significant when considering Medicare Part D (prescription drug coverage), but it also has implications for Medicare Parts A and B.

COBRA and Medicare Part B

When it comes to Medicare Part B, COBRA is not considered creditable coverage. Here’s why:

1. Primary vs. Secondary Coverage:
– COBRA is usually secondary to Medicare. If you are eligible for Medicare but choose to continue with COBRA, Medicare will typically become your primary insurer. This means that COBRA will only pay after Medicare has paid its share, which can lead to gaps in coverage and unexpected out-of-pocket expenses if you don’t enroll in Medicare when first eligible.

2. Avoiding Late Enrollment Penalties:
– If you delay enrolling in Medicare Part B because you have COBRA, you may face late enrollment penalties. The penalty for late enrollment is typically a 10% increase in your Part B premium for each 12-month period you could have had Part B but didn’t sign up. This penalty is usually permanent and can add up over time.

3. Special Enrollment Period (SEP):
– COBRA does not qualify you for a Special Enrollment Period (SEP) for Medicare. SEPs allow you to enroll in Medicare without penalty outside of your Initial Enrollment Period (IEP) under certain conditions, like having coverage through current employment. However, since COBRA is continuation coverage, not current employment coverage, it does not offer this protection.

COBRA and Medicare Part D

When considering Medicare Part D (prescription drug coverage), COBRA may or may not be considered creditable coverage. It’s essential to receive a notice from your COBRA plan indicating whether the prescription drug coverage is creditable. If it is deemed creditable, you can delay enrolling in Medicare Part D without facing a late enrollment penalty. However, you must ensure this information is clearly communicated to avoid future penalties.

Making the Transition from COBRA to Medicare

Given that COBRA is not creditable coverage for Medicare Part B, it is generally advisable to enroll in Medicare when you first become eligible. Here are some steps to ensure a smooth transition:

1. Evaluate Your Options: Compare the coverage and costs of COBRA versus Medicare. Consider enrolling in Medicare Part A (if premium-free) and Part B when you become eligible, even if you’re still covered by COBRA.

2. Check Enrollment Periods: Be mindful of your Initial Enrollment Period (IEP) and understand that COBRA does not provide a Special Enrollment Period (SEP) for Medicare Part B. If you miss your IEP, you may need to wait for the General Enrollment Period (GEP) and incur penalties.

3. Prescription Drug Coverage: If you have COBRA, check if your prescription drug coverage is creditable. If not, consider enrolling in a Medicare Part D plan to avoid future penalties.

4. Seek Professional Advice: Consult with a Medicare advisor or use resources available on to understand your specific situation and the best course of action.


COBRA is a valuable option for maintaining health coverage after employment ends, but it does not count as creditable coverage for Medicare Part B. To avoid late enrollment penalties and ensure comprehensive health coverage, it’s typically best to enroll in Medicare when you first become eligible. Understanding these nuances will help you make informed decisions about your healthcare coverage and avoid unnecessary costs in the future.


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About Mike Watts

Mike Watts is an independent insurance agent in Louisville KY