When Is the Medicare Supplement Special Enrollment Period?

A Medicare Supplement Special Enrollment Period restores your ability to enroll in Medicare Supplement (“Medigap”) at fair prices, even if your Medigap Open Enrollment Period is over. There are many ways to qualify for special enrollment.

In certain situations such as when you move, see significant changes in coverage, try out different Medicare programs, or otherwise lose your plan through no fault of your own, you’re automatically given a Medicare Supplement Special Enrollment Period.

While Special Enrollment Periods are typically shorter than your initial Open Enrollment Period, they still allow you to purchase Medicare Supplement coverage at the lowest rates. During special enrollment and open enrollment, you’ll be applying with guaranteed issue rights. These rights (also called “Medigap protections”) entitle you to the most favorable Medicare Supplement prices, without the risk of being denied care.

Below, we discuss all the situations that will qualify you for Medigap special enrollment.

Had Medicare Advantage or PACE Plan for Less Than a Year?

If you’ve been covered by a Medicare Advantage or PACE (Programs of All-Inclusive Care for the Elderly) plan for less than one year, then you may qualify for Medigap special enrollment. Under federal regulation, consumers have a “trial right”. This means that they have the right to sample plans like Medicare Advantage or PACE plan without incurring penalties.

You Qualify for a Special Enrollment Period Only if:

1. If you joined an Advantage plan as soon as you were Medicare-eligible and are switching to Original Medicare within a year (you never had Medigap).
2. If you had a Medigap plan but dropped it to switch to Medicare Advantage and want to switch back within a year (and this is your first time on a Medicare Advantage plan).

When Medigap Special Enrollment Period begins:

• Simply cancel your Medicare Advantage or PACE coverage during your first year and replace it with any Medigap plan.
• Your Special Enrollment Period starts 60 days before and lasts for 63 days after your previous coverage ends.
• Your Medigap policy can’t begin until your previous coverage (under Medicare Advantage or PACE) is finished, since Medigap plans only work with Original Medicare.

Have Medicare Advantage or Medicare SELECT & Want to Switch Back to Medigap?

If you switched from Medigap to Medicare Advantage or Medicare SELECT for the first time and want to switch back to Medigap, then you may qualify for a Medigap Special Enrollment Period.

You qualify for a Special Enrollment Period only if:

1. This was your first time leaving for a Medicare Advantage or Medicare SELECT plan and
2. You’ve been enrolled in that new plan for less than one year.

You have the guaranteed issue right to rejoin the Medigap plan that you switched away from, if it still exists. If that Medigap plan isn’t available, then you can switch to Original Medicare (Part A & B, managed by the federal government) and buy any Medigap Plan A, B, C, F, K, or L that’s available in your area (plans C and F are only available to enrollees who were eligible for Medicare prior to 2020). 

Note that in any case, you can apply for any Medigap plan you like at any time, but insurers can use medical underwriting if you’re applying for a plan that isn’t subject to the guaranteed-issue rules.

When Medigap Special Enrollment Period Begins:

• Your Special Enrollment Period starts 60 days before and lasts for 63 days after your previous coverage ends.
• Your Medicare Supplement policy can’t begin until your previous coverage is fully cancelled.

Issues with Your Medicare Advantage Policy?

If you experience certain issues with your current Medicare Advantage plan, then you may also qualify for a Medigap Special Enrollment Period.

You Qualify for a Special Enrollment Period Only if:

1. Your Medicare Advantage plan stops servicing your area;
2. You move out of your Medicare Advantage plan’s service area; or
3. Your Medicare Advantage plan exits the Medicare system.

If you qualify for special enrollment under this condition, then you’re allowed to enroll in Original Medicare and buy any Medigap Plan A, B, C, F, K, or L that’s available in your area (Plans C and F are only available to enrollees who were eligible for Medicare prior to 2020).

When Medigap Special Enrollment Period Begins:

• Your Special Enrollment Period starts 60 days before and lasts 63 days after your previous coverage ends.
• Your Medigap policy can’t begin until your previous Medicare Advantage coverage is finished.

Issues with Your Medicare SELECT Policy?

A Medicare SELECT policy is a Medigap plan with provider networks that is combined with Original Medicare.¹ If you experience issues with your Medicare SELECT policy, then you may qualify for a Medigap Special Enrollment Period.

You Qualify for a Special Enrollment Period only if:

• You move away from your Medicare SELECT plan’s coverage area – even if you still live in the same state.

If you qualify for special enrollment under this condition, then you’re allowed to purchase any Medigap Plan A, B, C, F, K, or L that’s available in your area (Plans C and F are only available to enrollees who were eligible for Medicare prior to 2020).

When Medigap Special Enrollment Period Begins:

• Your Special Enrollment Period lasts 63 days after your previous coverage ends.
• Your new Medigap policy can’t begin until your Medicare SELECT plan ends.

Have Original Medicare AND Group Health Coverage?

Instead of joining Medigap at age 65, you may have kept your old group health insurance plan and combined that with Original Medicare (Medicare Parts A and B, managed by the federal government). If you currently have both 1.) Original Medicare and 2.) group health coverage that helps you cover excess costs, then you may qualify for Medigap special enrollment if your group coverage is ending.

Keep in mind that people who enroll in Part A but delay Part B because they have current employer-sponsored coverage are eligible for their full Medigap initial enrollment period if and when they eventually enroll in Part B. 

You Qualify for a Special Enrollment Period only if:

1. Your group coverage ends;
2. You receive a cancellation notice from your current policy; or
3. You learn that your coverage has ended due to a denied claim.

If you qualify for special enrollment under this condition, then you’re allowed to purchase Original Medicare and Medigap Plan A, B, C, F, K, or L that’s available in your area (Plans C and F are only available to enrollees who were eligible for Medicare prior to 2020).

Not all private health insurance will qualify as group health coverage, though. Group health coverage generally includes:

• Coverage offered by your employer (“employer group health plan”);
• Retiree coverage;
• Union coverage; or
• COBRA coverage.

(Note that in order to delay Medicare Part B without a late enrollment penalty, the group coverage must be from a current employer — your own or your spouse’s — and cannot be COBRA or retiree coverage from a previous employer.)

When Medigap Special Enrollment Period begins:

• Your Special Enrollment Period ends 63 days after whichever of these was the last to occur.

If you have COBRA, you have the option to buy Medigap right away or wait until the COBRA ends.

Live in NY, CT, CA, ME, MO, OR, or WA?

State laws in New York and Connecticut require Medicare Supplement plans to be available year-round without price adjustments for age or health status. This means if you live in these states, you can apply for Medigap at any time. It’s guaranteed-issue so you don’t have to worry about a Medigap Special Enrollment Period.

In Massachusetts, there is an annual guaranteed-issue window in February and March for any enrollee to switch plans or enroll without having any of the Special Enrollment Period requirements.

If You Live in California, Maine, Missouri, Oregon, or Washington

These states have various windows, sometimes linked to your birthday or plan anniversary date, when you can enroll or switch plans – with some limits that vary by state – without having one of the triggering events normally required for a  Medigap Special Enrollment Periods. 

At certain times during the year, these five states allow you to transfer to any Medicare Supplement plan that has equal or lesser benefits to your current policy with a few caveats:

1. In Washington, you must have Medigap for 90-plus days and people with Plan A are limited to picking another Plan A. Those with other plans can switch to any available plan. 
2. In Maine, insurers must make Plan A guaranteed-issue for any enrollee, not just for people who already have Medigap, during one month each year.
3. In Missouri, enrollees are allowed to switch to a plan with the same benefits (ie, the same letter designation), but from a different insurer, during the month prior to their plans anniversary each year.

When Medigap Special Enrollment Period Begins:

• The actual Special Enrollment date depends on either 1.) your birthday or 2.) when you enrolled in your current plan.
• Check with your state insurance department or your preferred Medigap insurer for more information.

Did Your Medigap Issuer Go Bankrupt?

If your Medigap issuer went bankrupt (thereby terminating your coverage), then you may qualify for Medigap special enrollment.

You Qualify for a Special Enrollment Period Only if

1. Your Medicare Supplement provider goes out of business.

If you qualify for special enrollment under this condition, then you’re allowed to purchase any Medigap Plan A, B, C, F, K, or L (Plans C and F are only available to enrollees who were eligible for Medicare prior to 2020).

When Medigap Special Enrollment Period Begins

• Your Special Enrollment Period lasts for 63 days after your previous coverage ends or is fully canceled.

Did Your Current Policy Mislead You or Violate Medicare Rules?

If your insurance policy misled you, it’s a good idea to keep as much documentation on this issue as possible. If your Medigap or your Medicare Advantage policy misled you or violated Medicare rules, then you may qualify for a Medigap Special Enrollment Period.

You Qualify for a Special Enrollment Period Only if:

• You believe your current Medigap or Medicare Advantage policy may have misled you or violated Medicare rules and
• If you have documentation backing up these claims.

If you qualify for special enrollment under this condition, then you’re allowed to switch to Original Medicare (if you have a Medicare Advantage plan) and purchase any Medigap Plan A, B, C, F, K, or L (Plans C and F are only available to enrollees who were eligible for Medicare prior to 2020).

When Medigap Special Enrollment Period Begins

• You can purchase a new plan within a reasonable amount of time after learning about the rule violation.
• Your Special Enrollment Period lasts for 63 days after your previous coverage ends.

Did Your Medigap Policy End Due to Causes Unrelated to You?

Medicare recognizes that special circumstances occur. If your Medicare Supplement policy ends without your input and through no fault of your own, you can still acquire new Medigap coverage.

You Qualify for a Special Enrollment Period Only If:

• Your current Medigap policy ends abruptly out of nowhere through no fault of your own.

If you qualify for special enrollment under this condition, then you’re allowed to purchase Original Medicare and Medigap Plan A, B, C, F, K, or L (Plans C and F are only available to people who were already eligible for Medicare prior to 2020).

When Medigap Special Enrollment Period Begins:

• Your Special Enrollment Period lasts for 63 days after your previous coverage ends.

How to Ensure Continuous Coverage If You Qualify for Medigap Special Enrollment

You don’t have to spend a day without health insurance just because you’re switching plans. Just learn when your old coverage is ending, and let your new Medicare Supplement issuer know about your Special Enrollment Period. They can sign you up in advance so that your Medigap coverage is ready to start as soon as your old coverage ends.