Monday, July 2, 2012

Part D Disenrollment - Failure to Pay Premium Surcharge

Although extremely unlikely, you may get a nasty shock this month as beginning with April 1, 2012, Medicare will disenroll any beneficiary who was subject to the Part D premium surcharge and who did not pay it. When these individuals go to get a prescription filled, they will be told they are no longer in Part D, and will have to pay for the prescription by themselves. However, only somewhat over a thousand beneficiaries are involved at this point.


The premium surcharge is the extra amount that higher income beneficiaries must pay in addition to their Part D premiums. This surcharge ranges from $40.00 to $219.80 per month per beneficiary in 2012. It is called the “Part D-Income Related Monthly Adjustment Amount” (or “Part D-IRMAA”) as the government doesn’t want to call it a tax, which it really is. While most beneficiaries have this taken out of their Social Security (or Railroad Retirement) monthly payment, others have to pay it directly to Medicare. They may be a little confused because they may pay their monthly Part D premium to their Part D drug plan (or their Medicare Advantage Plan, if that is how they get their Part D), but the surcharge to Medicare. Apparently, there has also been some confusion as to whether or not beneficiaries enrolled in Part D through their employer group health plan are subject to this; they are.

At any rate, you probably got a letter sometime this winter warning you to pay your surcharge; if you did not pay, Medicare cut your Part D off April 1. Two important things: this affects your Part D, not your Part A or Part B. But it does affect Part C; if you are in a Medicare Advantage Plan that has Part D coverage, you will be disenrolled from it. (This is also true if you are in an employer group health plan that has Part D coverage.) And if you believe terminating your Part D is an error, or there has been some mix-up, you can ask for reconsideration of the termination by calling 1-800-MEDICARE, but be sure to do so within 60 days of your termination. Medicare has a policy to allow for reinstatement if the individual was unable to make timely payment due to an unusual and unexpected circumstance over which they had no control and that is not likely to happen again. Individuals who receive favorable determinations must pay all owed amounts within three months of disenrollment in order to get their coverage back.

You can also reenroll in Part D in the future, for example, during the 2012 open enrollment period (which begins October15), but you will have to pay any surcharges which are outstanding. And you may also be subject to the non-enrollment penalty.



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