Glossary
Working Past 65 (with Employer Coverage)
If you (or your spouse) are still working past 65 with employer group health coverage from a 20+ employee company, you can delay Part B penalty-free and keep TRICARE Prime/Select until employment ends.
Also known as: Delayed Part B enrollment, Active employment SEP
Quick answer
Active employer group health coverage from a 20+ employee company (yours or your spouse's) is the one scenario in which a Medicare-eligible person can legitimately delay Part B without penalty. The employer plan continues as primary; Medicare is not yet needed. When employment or coverage ends, you have an 8-month Special Enrollment Period to enroll in Part B with no late penalty.
Why it matters
This is the ONLY legitimate reason for a retired-military beneficiary to keep TRICARE Prime/Select past 65 instead of transitioning to TFL. All other reasons (TRICARE itself, VA care, COBRA, retiree FEHB) do NOT qualify and result in permanent late penalties + loss of TFL.
Why this matters at age 65
If you're working past 65, request a written 'Notice of Creditable Coverage' from your HR department and keep it on file. When employment ends, file CMS-40B (Part B application) and CMS-L564 (employer coverage certification) with SSA within 8 months to trigger your SEP.
When you'll encounter it
Any time you (or your covering spouse) are actively employed past 65 with employer health coverage.
Impact on Medicare
Permits delayed Part B enrollment without late penalty. Part A is still typically enrolled (unless you contribute to an HSA, in which case delay both).
Impact on TRICARE For Life
Keeps TRICARE Prime/Select active past 65 (since Medicare isn't required while employer coverage is primary). The moment employer coverage ends, transition to Medicare A+B and TFL using your 8-month SEP.
VA Healthcare considerations
VA care is irrelevant to the working-past-65 SEP. Only active employer coverage from a 20+ employee company qualifies.
Military-specific context
FEHB held by a federal RETIREE does not qualify (only active federal employment does). FEHB held by a still-working federal employee or spouse does qualify.
Common misconceptions
- "Employer coverage from any size company qualifies." — Only employers with 20+ employees. Small-employer plans become secondary to Medicare at 65, so you must enroll in Medicare on time anyway.
- "COBRA past 65 qualifies for an SEP." — It does not. The 8-month SEP clock starts when ACTIVE employment ends, not when COBRA ends.
- "If I keep working I can also keep TRICARE Prime without consequence." — Yes — but only because Medicare isn't required yet. The moment employment ends, you must enroll in Part B or lose TFL.
Common mistakes to avoid
- Working at a small (<20 employee) company past 65 and not realizing Medicare must be primary — late penalties accrue.
- Relying on COBRA to extend the Part B SEP — it does not.
- Forgetting to file CMS-L564 from the employer when ending coverage.
- Not coordinating spouse's coverage if she is also Medicare-eligible.
Real-world scenario: A retired Air Force colonel takes a corporate job at age 64. At 65 he's covered by a 5,000-employee company plan. He stays employed until 70.
He delays Part B at 65 with no penalty. Continues TRICARE Select as backup. At 70 he retires; HR provides CMS-L564; he files CMS-40B within 8 months. Part B effective the first of the next month; TRICARE Select terminates; TFL activates with no gap and no penalty.
What should I do?
- 1Request a written Notice of Creditable Coverage from HR and keep it on file.
- 2Confirm the employer has 20+ employees — small-employer plans do NOT qualify.
- 3Take premium-free Part A at 65 unless you're contributing to an HSA (which Part A disqualifies).
- 4When employment ends, file CMS-40B and CMS-L564 with SSA within 8 months — don't wait until COBRA ends.
- 5After Part B effective date, verify DEERS reflects A and B so TFL activates without gap.
Questions people commonly ask
- Can I delay Part B if I'm still working?
- Does my spouse's employer plan count?
- What about COBRA?
- Should I still take premium-free Part A?
Continue learning
— suggested by the knowledge graph- What is Medicare? A complete overview for retired militaryA plain-English, handbook-grounded overview of the federal health insurance program for people 65 and older, written specifically for retired service members and their families.
- Understanding Original Medicare (Parts A & B) for veteransExactly what Part A and Part B cover, what they cost in 2026, and why both are required to keep TRICARE For Life.
- Enrolling in Medicare: timing, methods, and the military-specific rulesWhen and how to sign up for Medicare Parts A and B — and the timing that protects your TRICARE For Life activation.
- Avoiding the Medicare late-enrollment penaltyThe Part B late penalty is permanent — and TRICARE does not waive it. Here's how to make sure you never owe it.
- Beneficiary CategoryHow DEERS classifies you (active duty, retiree, family member, survivor, etc.) — determines which TRICARE plans and cost shares apply.
- Creditable Drug CoveragePrescription drug coverage that CMS certifies is at least as good as standard Medicare Part D — including TRICARE Pharmacy and VA Pharmacy.
- Disability Medicare Eligibility (Under 65)Medicare eligibility before age 65 — automatic after 24 months of SSDI, immediately for ALS, and based on dialysis/transplant for ESRD.
- General Enrollment Period (GEP)The January 1 – March 31 window each year when you can sign up for Medicare if you missed your IEP and don't qualify for an SEP.
- IRMAA (Income-Related Monthly Adjustment Amount)An income-based surcharge added to your Medicare Part B and Part D premiums when your modified adjusted gross income exceeds CMS thresholds.
- I'm turning 65. What should I do first?About 3 months before your 65th birthday, sign up for Medicare Parts A and B at SSA.gov. TRICARE For Life activates automatically once both are effective and DEERS is current.
- Can I keep going to the military hospital after 65?Only on a space-available basis. Active duty and Prime enrollees come first. Most retirees on TFL transition fully to civilian Medicare providers.
- Is there an enrollment fee for TRICARE For Life?No. TFL has no enrollment fee and no monthly premium. The only premium you pay is for Medicare Part B.
- I'm still working past 65. Can I delay Part B?Only if you have true employer group health coverage from active employment (yours or your spouse's, 20+ employees). In that case you get a Special Enrollment Period later. But TFL won't activate until you take Part B.
- Do I need Medicare Part A if I have TRICARE?Yes. TFL requires Part A and Part B. Part A is typically premium-free if you or your spouse worked 40+ quarters paying Medicare taxes.
Related glossary terms
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Last reviewed January 2026 against the 2026 Medicare & You and TRICARE For Life handbooks.