Medicare Part B Special Enrollment Period

Hi all,

My husband and I are dual UK/US Citizens and we're in the process of transitioning from work to retirement.  A big part of our decision-making revolves around where we are going to live.   One possibility is to snowbird in Florida in the winter and stay somewhere else, either U.K. or elsewhere in Europe in the summer.  We are probably not going to be able to make a decision on this for a few years, and my husband will be 65 next year, so I'm trying to pin down the rules for Medicare Part B enrollment.

As far as I can tell, if we delay enrollment in Part B  past the age of 65, we will incur a penalty, unless we qualify for a "Special Enrollment Period".  Now this is where I get confused.  I can't clarify in what circumstances we would qualify for the Special Enrollment Period.  Apparently, if you continue to work or volunteer in a country with a National Health Service, you are eligible for the Special Enrollment Period.  However, it's not clear how much work is enough - is part-time OK?  How many hours or is there an amount you need to earn?  If self-employed, what are the rules?  If volunteering, how many hours and with whom? 

All I can find is very general information online. I want to make sure I have the accurate citations to Social Security Regulations  to make sure I have the correct proof to submit when and if we return to the US.  I'm trying to get through to the Federal Benefits Unit, but no-one picks up the phone.

Does anyone have any thoughts on this?

I have no experience of this but am interested in hearing the responses. One thing I believe is true is that if you don’t enroll in Part B then on returning to the USA you may not not be able to sign up for several months depending on when you move back, although that enrollment period is Jan- Mar so is probably exactly when you want to be out of the British winter.

https://www.medicareinteractive.org/get-answers/medicare-health-coverage-options/medicare-and-living-abroad/medicare-coverage-when-living-abroad#:~:text=If%20you%20are%2065%20or,no%20premium%20for%20Part%20A

If you fail to pay for Part B while abroad, when you move back to the U.S. you may go months without health coverage. This is because you may have to wait until the General Enrollment Period (GEP), which runs January 1 through March 31 each year, with coverage starting the first of the month after the month you enroll.

Hi all,

My husband and I are dual UK/US Citizens and we're in the process of transitioning from work to retirement.  A big part of our decision-making revolves around where we are going to live.   One possibility is to snowbird in Florida in the winter and stay somewhere else, either U.K. or elsewhere in Europe in the summer.  We are probably not going to be able to make a decision on this for a few years, and my husband will be 65 next year, so I'm trying to pin down the rules for Medicare Part B enrollment.

As far as I can tell, if we delay enrollment in Part B  past the age of 65, we will incur a penalty, unless we qualify for a "Special Enrollment Period".  Now this is where I get confused.  I can't clarify in what circumstances we would qualify for the Special Enrollment Period.  Apparently, if you continue to work or volunteer in a country with a National Health Service, you are eligible for the Special Enrollment Period.  However, it's not clear how much work is enough - is part-time OK?  How many hours or is there an amount you need to earn?  If self-employed, what are the rules?  If volunteering, how many hours and with whom? 

All I can find is very general information online. I want to make sure I have the accurate citations to Social Security Regulations  to make sure I have the correct proof to submit when and if we return to the US.  I'm trying to get through to the Federal Benefits Unit, but no-one picks up the phone.

Does anyone have any thoughts on this?

Unfortunately, the SSA has had a hiring freeze on for some time, so they are short-staffed.

https://www.ssa.gov/help/iClaim_medSEP.html - There are a number of links on this page to PDFs with detailed info

According to the regulations, as I read them, you have to be employed with healthcare coverage if you are over age 65 and want to forgo enrolling in Part B temporarily. Also to think about is Part D (drug coverage). It works in a similar fashion - if you don't enroll when first eligible, there's a penalty applied to future premium costs. 

I don't think employment outside the USA unless it's for a US government entity or company (or the armed forces) would count as employment for any special enrollment period for Medicare. I also don't believe any sort of voluntary work (again, except for a US entity) would either.  It's been several years since I was checking on that (when I was in the UK), but I'm pretty sure that work outside the USA (with a few exceptions) was not applicable here.  If you're working in the USA or for a US entity, you're still contributing to Medicare via tax deductions from your paycheck. If you're working abroad otherwise, or once you retire, you are not. (As a retiree I had health insurance through my former employer, but it would not count for a SEP for me when I returned to the USA.)  Hopefully I'm wrong and you can find somewhere that the govmt publishes info to the contrary, but I'm pretty sure that's how it goes. Sorry!

From the link referenced above:



If you are age 65 or older, you or your spouse are still working and you are covered under a group health plan based on that current employment, you may not need to apply for Medicare medical insurance (Part B) at age 65. You may qualify for a "Special Enrollment Period" (SEP) that will let you sign up for Part B:

    *During any month you remain covered under the group health plan and your, or your spouse's, current employment continues; or
    *In the eight-month period that begins with the month after your group health plan coverage or the current employment it is based on ends, whichever comes first.

    Exception: If your group health plan coverage or the employment it is based on ends during your initial enrollment period for Medicare Part B, you do not qualify for a SEP. Your initial enrollment period starts three months before the month you attain age 65 and ends three months after the month you turn 65.     

   *If your group health plan coverage is based on severance or retirement pay and the job your coverage is based on ended in the last eight months.


Note: COBRA and retiree health plans aren't considered coverage based on current employment. If you have that type of coverage, you will not be eligible for a SEP when it ends. To avoid paying a higher premium, make sure you sign up for Medicare when you are first eligible.

People who receive Social Security disability benefits and are covered under a group health plan from either their own or a family member's current employment also have a special enrollment period and premium rights similar to those for workers age 65 or older.

If you want to know more about enrollment periods for Part B, please read the information about general and special enrollment periods in the "Signing up for Medicare" section of our "Medicare" booklet or talk to your personnel office.


The link in the previous post (from Medicareinteractive.org) does seem to say it's possible, though.  As does this doc https://secure.ssa.gov/poms.nsf/lnx/0600805266Good luck!

Hmm, this is all very interesting and helpful!
I'm just starting to look at the regulations and found this:

HI 00805.295 Evidence of GHP or LGHP Coverage Based on Current Employment Status
E. Policy for countries with national health plans
Consider health plans in countries that have national health plans (also called Universal Healthcare) to meet the definition of a GHP for purposes of the SEP and premium surcharge rollback.

A beneficiary (or a spouse) requesting an SEP or premium surcharge rollback who worked in a country with a national health plan must provide evidence of employment and evidence of coverage under the national health plan.  Evidence of employment includes statements from the employer, income tax returns, pay statements, or any other verification of employment. Evidence of coverage under the national health plan may be in any form as long as it is from an official source (e.g., statement from the employer or the plan, income tax returns) and clearly reflects that the beneficiary has or had coverage under the national health plan.

So it does seem that if one of us was working after aged 65, and we could provide evidence of that and something official showing our coverage under the NHS, we would be eligible to defer paying Medicare Part B without a penalty.  There doesn't seem to be any reference to the employment being with a US company, but I will confirm.  This info will be helpful when I talk to the Embassy and the SSA.  I've also contacted Democrats Abroad as they have been very helpful in the past with various tax and investment issues.

Thanks very much for the information and I will update when I find out more!
Regards, Julie

Hi Julie -

I did just find this for you - https://www.aarp.org/health/medicare-qa-tool/medicare-if-living-outside-united-states.html