Medicare and Working Past 65 — What You Need to Know in 2026
One of the most common and consequential Medicare decisions seniors face is what to do when they are still working at age 65. Should you enroll in Medicare right away? Can you delay enrollment without penalty? What happens to your employer coverage? Getting this wrong can result in permanent late enrollment penalties, unexpected gaps in coverage, or paying for duplicate insurance you don’t need. If you’re turning 65 soon, our Turning 65 guide is a great place to start. This guide explains exactly how Medicare works when you’re still employed at 65, so you can make the right decision for your situation.
Do You Have to Enroll in Medicare at 65 If You Are Still Working?
The short answer is it depends. Whether you need to enroll in Medicare at 65 while still working depends primarily on two factors:
- The size of your employer — how many employees does your company have?
- Whether your coverage is considered “creditable,” does it meet Medicare’s minimum standards?
These two factors determine whether you can safely delay Medicare enrollment without facing permanent penalties later.
Large Employer vs Small Employer — The Critical Difference
Working for a Large Employer (20+ Employees)
If you work for a company with 20 or more employees and have employer-sponsored health insurance, your employer plan is considered the primary payer, meaning it pays your medical bills first. Medicare would be secondary.
In this situation, you can generally delay Medicare enrollment without penalty as long as you remain actively employed and covered by the employer plan. When you eventually leave your job or lose your employer coverage, you will have a Special Enrollment Period to sign up for Medicare without penalty.
Working for a Small Employer (Fewer than 20 Employees)
If your employer has fewer than 20 employees, the rules flip completely. Medicare becomes the primary payer, and your employer plan becomes secondary. This means:
- Your employer plan may pay little or nothing if Medicare hasn’t paid first
- You should enroll in Medicare Parts A and B at 65 to avoid coverage gaps
- Failing to enroll could leave you with significant unpaid medical bills
This is one of the most dangerous Medicare mistakes small business employees make, assuming their employer coverage is enough without checking whether Medicare needs to be primary.
Medicare Part A — Should You Enroll at 65 Even If Still Working?
For most people, the answer is yes, enroll in Part A at 65, regardless of your work status. Here’s why:
- Medicare Part A is premium-free for most people
- It provides a secondary layer of hospital coverage at no cost
- There is no penalty for enrolling in Part A while still working
- It can help cover costs that your employer plan doesn’t
Exception: If you contribute to a Health Savings Account (HSA) you cannot contribute to your HSA once you enroll in any part of Medicare, including Part A. If maximizing HSA contributions is important to you, you may want to delay Part A enrollment until you stop working.
Medicare Part B — When to Enroll
Medicare Part B has a monthly premium of $202.90 in 2026, so the decision to enroll is more nuanced than Part A. For a full breakdown of what you’ll pay across all parts of Medicare, visit our Medicare Costs 2026 page.
Large Employer (20+ Employees) — You Can Delay Part B
If you have qualifying employer coverage through a large employer, you can delay Part B enrollment without penalty. When your employment ends, or you lose your employer coverage, you have an 8-month Special Enrollment Period to enroll in Part B without a late penalty.
Small Employer (Fewer than 20 Employees) — Enroll in Part B at 65
If your employer has fewer than 20 employees, you should enroll in Part B at 65. Medicare is primary for small employer plans, and not enrolling could result in large unpaid medical bills.
The Part B Late Enrollment Penalty — A Permanent Consequence
If you delay Part B enrollment without a qualifying reason, you will face a permanent late enrollment penalty. The penalty is 10% of the Part B premium for every 12-month period you were eligible but did not enroll. This penalty lasts for as long as you have Medicare.
For example, if you delayed Part B for 3 years without a valid reason, your monthly premium would be permanently increased by 30%. Use our Part B Late Enrollment Penalty Calculator to see exactly what your penalty would be.
What About COBRA Coverage?
COBRA coverage is one of the most misunderstood situations in Medicare enrollment. Here’s what you need to know:
- COBRA is NOT considered creditable coverage for Medicare enrollment purposes
- If you delay Medicare enrollment because you have COBRA, you will face late enrollment penalties
- When your active employer coverage ends, you have an 8-month SEP to enroll in Medicare, but COBRA does not extend this window
- Always enroll in Medicare before or when COBRA begins if you are 65 or older
Special Enrollment Period When You Stop Working
When you stop working or lose your employer coverage, you qualify for a Special Enrollment Period (SEP) to sign up for Medicare. This SEP lasts 8 months from the date your employment or employer coverage ends — whichever comes first. For a deeper look at all Medicare enrollment windows, visit our guide on Medicare Enrollment Periods Explained.
Important — don’t wait until the last minute. It’s best to enroll in Medicare before your last day of work to ensure there is no gap in coverage.
Retiree Coverage and Medicare
If your employer offers retiree health coverage after you leave your job, Medicare typically becomes your primary insurance, and your retiree plan becomes secondary. The specifics depend on your retiree plan — always review the coordination of benefits rules carefully before retiring.
Common Mistakes to Avoid
- ❌ Assuming COBRA qualifies as creditable coverage — it does not for Medicare purposes
- ❌ Not checking your employer’s size — the 20-employee rule changes everything
- ❌ Waiting too long after leaving your job — you have 8 months, not indefinitely
- ❌ Enrolling in Part A while still contributing to an HSA — this creates a tax problem
- ❌ Assuming your spouse’s employer plan protects you — the same rules apply
Frequently Asked Questions
Can I stay on my employer plan past 65 and skip Medicare?
If you work for a large employer (20+ employees) and have qualifying employer coverage, yes, you can generally delay Medicare Part B without penalty. However, you should still enroll in Part A unless you are contributing to an HSA.
What if my spouse is still working and I’m on their plan?
The same rules apply if your spouse’s employer has 20 or more employees, and you are covered under their plan; you can generally delay Medicare without penalty. The employer size is what matters, not whose name is on the policy.
What is creditable coverage?
Creditable coverage is employer-sponsored health insurance that meets Medicare’s minimum standards. Most employer group health plans qualify as creditable coverage for Part B. For Part D, creditable drug coverage means your employer plan covers at least as much as Medicare’s standard drug benefit.
How do I prove I had employer coverage when I enroll in Medicare?
Your employer will provide a letter confirming your coverage dates. You submit this with your Medicare enrollment application to avoid late penalties. Always keep documentation of your employer coverage periods.
Do I need a Medicare broker if I’m still working?
Working with an independent broker is especially valuable when you’re still employed at 65. The rules around employer size, creditable coverage, and enrollment timing are complex. Best of all, a Medicare broker costs you nothing — carriers pay brokers directly, so you always get unbiased guidance at no cost.
Still Working at 65? Get Expert Guidance Before Making Any Decisions
Medicare enrollment decisions made while still working are among the most consequential and most commonly misunderstood in all of Medicare planning. A mistake here can result in permanent penalties, coverage gaps, or unnecessary premium costs.
As an independent Medicare broker, I help working seniors navigate this transition carefully and correctly, completely free of charge. I serve clients in New York, New Jersey, and nationwide.
📞 Call (917) 740-1895 or book your free consultation online today.
We are not connected with or endorsed by the United States Government or the federal Medicare program. We do not offer every plan available in your area. Any information we provide is limited to those plans we do offer in your area. Please contact Medicare.gov or 1-800-MEDICARE to get information on all of your options.
Craig Smith
Independent Medicare Insurance Broker | AHIP Certified
Craig Smith is the founder of Craig Smith Insurance Group, an independent Medicare brokerage serving seniors across New York, New Jersey, and nationwide since 2013. With over 25 years of financial services experience and 317+ five-star Google reviews, Craig helps clients compare Medicare Advantage, Medicare Supplement, and Part D plans — always free of charge.
Learn more about Craig →










