If a beneficiary declined Part B coverage (for whatever reason) and later chooses to enroll in Part B during the General Enrollment Period, what are his Medicare Advantage enrollment options?

The Part B General Enrollment Period is from January 1st to March 31st of each year. This GEP has a coordinating SEP that allows a beneficiary to enroll in Part D between April 1st and June 30th with coverage effective on July 1st. Since someone who declined Part B coverage was not eligible for Medicare Advantage, this SEP coincides with the beneficiary's Initial Coverage Election Period (ICEP), the period when a newly MA-eligible beneficiary may enroll in an MA plan. Because this SEP and ICEP coincide, a beneficiary is permitted to enroll in an MA-PD plan from April 1st to June 30th, with coverage effective on July 1st.

Source: Section 30.2 of the MA Enrollment Guidance addresses enrollment options for those newly eligible for MA. The sentences in bold relate to this particular instance.

30.2 - Initial Coverage Election Period (ICEP)

The ICEP is the period during which an individual newly eligible for MA may make an initial election to enroll in an MA plan. This period begins three months immediately before the individual's first entitlement to both Medicare Part A and Part B and ends on the later of:

1. The last day of the month preceding entitlement to both Part A and Part B, or;

2. The last day of the individual's Part B initial enrollment period.

The initial enrollment period for Part B is the seven (7) month period that begins 3 months before the month an individual meets the eligibility requirements for Part B, and ends 3 months after the month of eligibility. See 42 CFR 407.14 for additional information.

30.2.1 - Initial Enrollment Period for Part D (IEP for Part D)

The Initial Enrollment Period for Part D (IEP for Part D) is the period during which an individual is first eligible to enroll in a Part D plan. In general, an individual is eligible to enroll in a Part D plan when he or she is entitled to Part A OR is enrolled in Part B, AND permanently resides in the service area of a Part D plan.

At the beginning of the Medicare prescription drug coverage program, all current Part D eligible individuals had an IEP for Part D that began on November 15, 2005, and ended on May 15, 2006. During the IEP for Part D, individuals may make one Part D enrollment choice, including enrollment in an MA-PD plan.

Generally, individuals will have an IEP for Part D that is the same period as the Initial Enrollment Period for Medicare Part B. The initial enrollment period for Part B is the seven (7) month period that begins 3 months before the month an individual meets the eligibility requirements for Part B, and ends 3 months after the month of eligibility. See 42 CFR 407.14 for additional information.

Individuals not eligible to enroll in a Part D plan at any time during their initial enrollment period for Medicare Part B or those not eligible for Part D during the first Medicare initial enrollment period for Part D (November 15, 2005 through May 15, 2006) have an IEP for Part D that is the 3 months before becoming eligible for Part D, the month of eligibility, and the three months following eligibility for Part D. Individuals eligible for Medicare prior to age 65 (such as for disability) will have another Initial Enrollment Period for Part D based upon attaining age 65.

The ICEP and the IEP for Part D occur together as one period when a newly Medicare eligible individual has enrolled in BOTH Part A and B at first eligibility. Should an individual delay enrollment in Part B to a later time, the ICEP and IEP become separate with the ICEP changing to then occur as the 3 months immediately preceding entitlement to BOTH parts A and B.

If a Medicare entitlement determination is made retroactively, an individual has not been provided the opportunity to enroll in a Part D plan during his/her IEP for Part D. Therefore, the IEP begins the month the individual receives the notice of the Medicare entitlement determination and continues for three additional months after the month the notice is provided. The effective date is generally the first day of the month after the organization receives a completed enrollment request.

In MA context, the IEP for Part D applies only to MA-PD enrollment elections. Accordingly, when an applicant has both the ICEP and IEP available to him/her, the organization must submit the transaction to CMS as an IEP election.

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