A Primer for Employers on Medicare Coordination of Benefits
October 23, 2023
 Primer for Employers on Medicare Coordination of Benefits

When a plan participant or beneficiary has Medicare and other health insurance, such as group health plan insurance, retiree coverage or Medicaid, there can often be confusion as to which insurance pays first on claims. Coordination of benefits (COB) rules, which are specified in plan documents or insurance policies, decide which insurance pays first. One plan is considered the primary payer that covers most expenses, while the secondary plan covers any remaining allowable expenses not covered by the primary plan. The COB allows health plans to provide health or prescription drug coverage to individuals receiving Medicare to determine their payment responsibilities. This helps ensure that the total amount paid by all insurance plans does not exceed the total costs of the health care expenses for Medicare-covered services and items.


This article provides a general overview of COB rules under Medicare.


How Does Medicare Work With Other Insurance?

There are many important facts to remember regarding how other insurance works with Medicare-covered services and items, such as the following:


  • The primary payer pays first and up to its coverage limits.
  • The secondary payer only pays if there are costs the primary payer doesn’t cover.
  • The secondary payer, which may be Medicare in certain situations, might not pay all the uncovered costs from the primary payer.
  • If a group health plan or retiree coverage is the secondary payer, the individual may need to enroll in Medicare Part B before that insurance would pay.


If a Medicare-covered individual’s other health insurance is the primary payer and fails to promptly pay a claim, typically within 120 days, that individual’s doctor or service provider may bill Medicare. Medicare can make a conditional payment for the individual’s claim, recovering any payments the primary payer should have paid at a later date.


What’s a Conditional Payment?

A conditional payment is a payment Medicare makes for services for which another payer may be responsible. Medicare makes this payment, so the plan participant or beneficiary won’t have to pay the claim. The payment is conditional because it must be repaid to Medicare if the Medicare-covered individual receives a settlement, judgment, award or other payment later.


Who Pays First?

When an individual has Medicare and other insurance, there are rules for whether Medicare or the other insurance is the primary payer for Medicare-covered services and items.


Medicare is typically the primary payer for Medicare-covered services and items in the following circumstances:


  • An individual is covered by only Medicare and Medicaid.
  • An individual covered by Medicare refuses group health coverage.
  • Medical services or supplies are not covered under a group health plan but are covered under Medicare.
  • A Medicare-covered individual is covered by a group health plan but has exhausted their coverage under the group health plan.
  • A Medicare-covered individual is 65 or older and covered by a group health plan (because the individual or their spouse is still working) offered by an employer with fewer than 20 employees.
  • A Medicare-covered individual is 65 or older and covered by an employer group health plan after retirement.
  • A Medicare-covered individual is 65 or older (or disabled) and covered by Medicare and the Consolidated Omnibus Budget Reconciliation Act (COBRA) coverage.
  • A Medicare-covered individual is disabled and covered by a large group health plan offered by an employer with fewer than 100 employees.
  • A Medicare-covered individual has end-stage renal disease and is enrolled in a group health plan or COBRA (after 30 months of eligibility or entitlement to Medicare).
  • A Medicare-covered individual has only Medicare and TRICARE coverage unless the individual is on active duty and receives services and items from a military hospital, clinic or other federal health care provider.


For a complete list of situations where Medicare is the primary payer, visit Medicare.gov or review the Centers for Medicare and Medicaid Services’ guide, Medicare & Other Health Benefits: Your Guide to Who Pays First.


How Does Medicare Know if an Individual Has Other Coverage?

COB permits an individual’s Medicare eligibility information to be shared with other payers and sends Medicare-paid claims to secondary payers for payment. The Benefits Coordination and Recovery Center (BCRC) does the following on Medicare’s behalf:


  • Collect and manage information on other types of coverage an individual with Medicare may have.
  • Determine whether an individual’s other coverage pays before or after Medicare.
  • Pursue repayment when Medicare makes a conditional payment.


Medicare doesn’t automatically know if a Medicare-covered individual has other health insurance; however, insurers are required to notify Medicare when they’re responsible for paying first for Medicare-covered services and items. In some instances, the individual’s health care provider, employer or insurer may ask them about their current coverage so they can report that information to Medicare. Additionally, insurers must report coverage changes to Medicare.


Summary

Understanding COB rules is vital to ensuring that a Medicare-covered individual’s claims are paid correctly. While COB rules can be complex, they can help Medicare plan participants and beneficiaries make the best use of their health care coverage.


For more health care resources, contact Simco today.

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Many businesses rely on multiple vendors to manage critical functions such as HR, payroll/HCM, benefits, commercial insurance, and retirement plans. While outsourcing can provide specialized expertise in each area, using separate providers often creates hidden costs that can quietly undermine efficiency, accuracy, and employee satisfaction. Here’s why integration matters, and how a consolidated approach can save time, reduce risk, and improve the employee experience. 1. Increased Administrative Burden When each service is managed by a separate vendor, administrative work multiplies. Employees and HR teams may spend extra hours logging into different systems to process payroll, submit benefits updates, or manage compliance tasks. Reconciling employee information across multiple portals and coordinating communications between vendors creates unnecessary complexity, which can distract your team from strategic priorities. 2. Higher Risk of Errors and Compliance Issues Fragmentation can increase the likelihood of costly mistakes. Payroll errors, mismanaged retirement contributions, and insurance coverage gaps often occur when systems do not communicate effectively. A single misalignment can have a ripple effect: Incorrect payroll deductions Late or missing retirement contributions Gaps in insurance coverage or compliance violations With multiple vendors, the risk of these errors and their consequences rises. 3. Limited Visibility and Reporting When each service lives in its own system, it’s hard to get a complete picture of your workforce. Without centralized reporting, many businesses struggle to: Analyze labor costs or benefits spending accurately Identify compliance gaps or coverage issues Track trends in employee engagement and retention Limited visibility makes it difficult to make informed decisions and optimize operations. 4. Compounded Costs Paying multiple vendors for separate services often results in more than just the sum of their fees. Each system typically comes with its own implementation, training, and subscription costs, which can quickly add up. In addition, internal administrative hours spent managing vendor relationships, reconciling conflicting data, or troubleshooting errors create a hidden expense that is often overlooked. Businesses may also face unexpected costs when trying to integrate or transfer data between disconnected platforms, or when compliance issues arise due to misaligned processes. Over time, these scattered costs compound, reducing overall efficiency and limiting resources that could be better spent on strategic growth initiatives. 5. Frustrated Employees The impact of fragmentation extends to employees. They may face confusion about where to access benefits or payroll information, experience delays in issue resolution, or encounter inconsistent communications. This frustration can lead to disengagement, lower productivity, and higher turnover. Businesses that integrate these functions provide a smoother, more cohesive experience for employees, resulting in higher satisfaction, better engagement, and a stronger workplace culture. Why Integration Matters Integrating HR, payroll/HCM, benefits, commercial insurance, and retirement services with a single partner simplifies operations, reduces errors, improves reporting, and enhances the employee experience. Businesses that consolidate services gain: Streamlined administrative processes and reduced duplication of effort Improved accuracy and compliance through connected systems Enhanced visibility into workforce metrics and financials Cost efficiencies by eliminating overlapping fees and redundant systems A more consistent, positive experience for employees By managing these services in a unified platform, your business can focus on growth instead of juggling multiple systems and vendors. Take the Next Step If your business is managing multiple vendors for HR, payroll, benefits, insurance, and retirement, it’s time to consider a more integrated approach. Streamlining these services with a single, high-touch partner like Simco can save time, reduce risk, and create a better experience for both your team and your employees.
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