Personal Finance (Not Investing) • FEHB Retirees can now delay Medicare B w/o Penalty?

What if we walk through the Part B application mechanics of a federal employee who retired before age 65, maintained FEHB coverage, and applies for Part B after age 65. It is my understanding the retiree would need to submit CMS-40B. The first question in Section 2 says:

1. Do you have (or did you have) coverage through an employer or union group health plan
since you turned 65? (If yes, complete item 3.) ..

Presumably they would answer yes because of the FEHB coverage. If they answer yes, then they must also complete item 3 which requires

1) Dates of health coverage
2) Dates of employment
3) The employer to complete CMS-L564, "Medicare Request for Employment Information."

The dates of health coverage would be provided and the "not ended" box would be checked.
The dates employment would be provided and the "not ended" box unchecked.
The purpose of the CMS-L564 is:

Use this form to show proof of group health plan coverage based on current employment so you can enroll
in Medicare. You complete Section A of this form, then ask your employer to fill out Section B.

This has already gone off the rails. The dates of employment and health coverage won't line up. Likewise, they won't be able to submit the CMS-L564 (there is no employer). It is my understanding that SSA/Medicare would then process this application only in a General Enrollment Period (GEP) and there would be a late enrollment penalty. There is no, "BUT I was a Federal Employee" box.

I am MORE than happy to be wrong, but what is the path that the retiree would take to avoid the penalty?

Statistics: Posted by tj — Mon Oct 27, 2025 9:38 pm — Replies 83 — Views 12694