Under COBRA rules, group health plans may terminate coverage early if a qualified beneficiary becomes entitled to Medicare after electing COBRA. But it’s important to understand what “entitled” really means.

Entitlement vs. Eligibility:

  • Eligible means the person qualifies for Medicare (e.g., due to age or disability).
  • Entitled means they’ve enrolled in Medicare and are receiving benefits.

Someone who is eligible but hasn’t enrolled yet is not considered entitled—and their COBRA coverage should continue.

When Does Entitlement Begin?

  • For Medicare Part A, entitlement is automatic if the person is already receiving Social Security or Railroad Retirement benefits. Otherwise, they must apply.
  • Medicare Part B entitlement typically begins when Part A does, or during a later enrollment period.

Important:
Only the individual who becomes entitled to Medicare can have their COBRA coverage terminated early. Other family members on COBRA—like a spouse or dependents—can continue their coverage.

Before ending COBRA early, confirm that the individual is enrolled in Medicare—not just eligible.

Source: Thomson Reuters