IBM Extend Health versus Medicare enrollment periods

Extend Health told us that our enrollment period to participate in IBM HRA or IBM FHA subsidies in 2014 is from October 1, 2013 - December 31, 2013. If you enroll by the last day of December 2013 you will be covered by your new insurance starting January 1, 2014. If you do not enroll by the end of 2013 you still will be able to enroll for two more months but depending on the state you live in and the plans you pick different enrollment rules might apply. AND you will not have health insurance until the first day of the month after you enroll.  So it is not wise to do it.  This is happening because there are two things going on for us this year.  It has to do with Medicare enrollment periods. Medicare law defines several types of enrollment periods.

• Medicare open enrollment for 2014 is from October 15 - December 7, 2013.  During open enrollment (which happens every year) all Medicare eligible recipients are able to change their health insurance plans to be Original Medicare or  a new Medicare Advantage and/or a new Prescription Drug (part D) plan for the next year.
     
• Medigap plans ARE NOT part of the Medicare open enrollment window.  Medigap enrollment rules vary widely from state to state.  For example, New York allows you to change or get a Medigap plan whenever you want and insurance companies cannot deny you but you might have a 6 month wait to cover pre-existing condition clause.  California allows you to change once a year on your birthday.  Some states only require insurance companies to sell you a medigap when you first turn 65.  All states have a guarantee issue requirement that insurance companies must sell you a medigap plan (albeit with the 6 month pre-existing wait) when your prior plan is ending.  This is our case - our corporate plan is ending.  In Medicare parlance - it is called a special enrollment period or an SEP.
     
• Medicare Special Enrollment Period is provided to us because our IBM corporate plan is ending.  SEPs are provided for A LOT of reasons - not just when an existing plan ends. Because our IBM insurance is ending we have an SEP that starts on December 8 and goes until the last day of February 2014.  To find out all 17 SEPs available and all the rules go to: http://www.medicareinteractive.org/uploadedDocuments/mi_extra/SEP-Chart.pdf.  Our SEP is defined as reason # 12 and is a ONE TIME SEP. So, if you enroll after December 7, 2013 you will not be allowed to change your choices after you do it. I am not clear how Extend Health will deal with all the SEPs and will be asking more questions about it the next time I talk to an agent.
     
• Medicare Advantage Disenrollment Period is from January 1, 2014 - February 14, 2014.  If you are dissatisfied with the Medicare Advantage plan you choose you can disenroll and go back to original Medicare and get a part D drug insurance plan.  HOWEVER, you might not be able to buy a medigap plan.  It depends on the rules in your state whether an insurance company is required to sell you a plan and the SEP will no longer apply since prior plan SEP is a one time thing that you used up in 2013. Again, I don't know how Extend Health works with the MADP but it is an important question to ask.