This article covers how agents and brokers can assist clients who are transitioning between ACA Marketplace coverage and Medicare, including how to terminate Marketplace coverage, how to handle household members who are continuing their Marketplace coverage, and when to call the Marketplace Call Center instead of making changes online.
Key Terms
Key Terms
Initial Enrollment Period (IEP): A 7-month window during which a consumer can first sign up for Medicare. For most consumers, the IEP begins 3 months before their 65th birthday, includes the month of their birthday, and ends 3 months after their birthday month.
Special Enrollment Period (SEP): A time outside of Open Enrollment when a consumer can enroll in or change their Marketplace coverage due to a qualifying life event or other specific circumstance.
Advance Payments of the Premium Tax Credit (APTC): Federal financial assistance paid directly to a consumer's insurance carrier to reduce their monthly Marketplace premium. APTC amounts may change when a household member with Medicare is removed from a Marketplace plan.
Accumulators: Tracking totals for cost-sharing amounts a consumer has paid toward their deductible, out-of-pocket maximum, or other plan limits during a coverage year. Accumulators may reset when a consumer selects a new Marketplace plan.
Enhanced Direct Enrollment (EDE): A CMS-approved process that allows agents, brokers, and web-brokers to complete Marketplace applications and enrollments directly through a partner website without sending consumers to HealthCare.gov.
Can a client keep their Marketplace plan while waiting for Medicare to start?
Yes. A consumer can keep their Marketplace plan without penalty until their Medicare coverage starts. Alternatively, a consumer can choose to terminate their Marketplace plan when they enroll in Medicare. The decision depends on the consumer's coverage needs and the timing of their Medicare start date.
Once Medicare eligibility begins, consumers have a 7-month Initial Enrollment Period (IEP) to sign up. For most consumers, the IEP begins 3 months before their 65th birthday, includes the month of their birthday, and ends 3 months after their birthday month.
How do I help a client terminate their Marketplace plan when they enroll in Medicare?
You can assist a client with terminating their Marketplace plan in any of the following ways:
Help them end their coverage through an Enhanced Direct Enrollment (EDE) website.
Direct them to HealthCare.gov to manage the termination themselves.
Call the Marketplace Agent/Broker Partner Line at 1-855-788-6275 on their behalf.
If the consumer is managing the termination themselves through their HealthCare.gov account, they should navigate to "My plans and programs" and select "End (Terminate) All Coverage."
How do I help a client keep their Marketplace plan until their Medicare start date?
Consumers who want Marketplace coverage until their Medicare begins should update their Marketplace application online or by phone through the Marketplace Call Center. On the application — either on HealthCare.gov or on an EDE website — the consumer will be asked whether they are starting Medicare within the next three months. The consumer can provide their Medicare start date, enroll in a Marketplace plan, and the Marketplace will automatically end their Marketplace coverage at the appropriate time.
What happens to other household members on the same Marketplace plan when a consumer transitions to Medicare?
If other household members are continuing their Marketplace coverage after the Medicare enrollee is removed from the plan, their APTC amount and premium responsibility may be updated. Those continuing enrollees may be eligible to shop for a new Marketplace plan if they qualify for a Special Enrollment Period (SEP).
If the person transitioning to Medicare is the subscriber on the Marketplace policy, the remaining household members will need to select the same plan or a new plan. When they do, their accumulators — such as their deductible progress or annual out-of-pocket limit — may reset. For clients transitioning from an ACA Family Plan to Medicare Advantage due to aging into MA eligibility, agents must contact CMS to remove the individual from the family plan.
Are there situations where I should not make changes online and must call the Marketplace Call Center instead?
Yes. When a Marketplace enrollee started Medicare in the past or is starting Medicare in the next month, and someone on the same application also needs to add a newborn born in the last 60 days or report an adoption that occurred in the last 60 days, the consumer must call the Marketplace Call Center at 1-800-318-2596 rather than making changes online. Making changes online in this scenario risks a gap in coverage for the consumer transitioning to Medicare.
Can a client who must pay for Medicare Part A keep their Marketplace plan and subsidy?
Yes. If your client is turning 65 but does not qualify for premium-free Medicare Part A (fewer than 40 work quarters, roughly 10 years of Medicare-covered employment), they can choose not to enroll in Medicare, keep their Marketplace plan, and keep their premium tax credit — as long as they still qualify for the subsidy on income and the other usual requirements.
Eligibility for premium-free Part A counts as minimum essential coverage whether or not the person enrolls — so people entitled to premium-free Part A lose subsidy eligibility at 65 regardless of what they do. But someone who would have to pay a premium for Part A is only treated as having Medicare if they actually enroll. If they don't enroll, they remain subsidy-eligible on the Marketplace.
The distinction is premium-free vs. premium Part A:
Premium-free Part A (40+ quarters, or eligible through a spouse): subsidy eligibility ends when Medicare eligibility begins, whether or not they enroll.
Premium Part A (must pay for it): no enrollment, no Medicare — Marketplace subsidy can continue.
What should I tell a client before they stay on the Marketplace instead of enrolling in premium Part A?
1. Late-enrollment penalties build while they wait. Marketplace coverage is not creditable coverage for Medicare. If your client later enrolls in Medicare — because premium-free Part A becomes available, the subsidy shrinks, or their needs change — they may face the lifelong Part B late-enrollment penalty (10% for each full 12-month period they delayed), a Part A premium penalty, and a wait for an enrollment period. Staying on the Marketplace is a legitimate choice, but reversing it later has a cost.
2. Premium-free eligibility can arrive later through a spouse. A client can become entitled to premium-free Part A on a spouse's work record (generally when the spouse is 62 or older, including certain divorced and widowed situations). The moment premium-free eligibility exists through any route, the exception ends and subsidy eligibility ends with it. Revisit this at every renewal.
3. Very low income? Check Medicaid and Medicare Savings Programs first. Clients at the lowest income levels may qualify for a Medicare Savings Program (such as QMB) that pays the Part A premium for them — which usually beats the Marketplace math. The keep-ACA strategy fits the middle income band, not the lowest.
4. Run the actual numbers. The real comparison is the client's subsidized net Marketplace premium versus purchased Part A plus Part B plus a Medicare plan. Purchased Part A alone can run several hundred dollars per month, so for clients without the work quarters, the Marketplace often wins decisively — but show the client the comparison rather than assuming.
Paid Part A and Marketplace subsidy — quick reference
Client situation at 65 | Marketplace subsidy? |
Qualifies for premium-free Part A (own or spouse's work record) | No — subsidy ends when Medicare eligibility begins, even if they don't enroll |
Would have to pay for Part A, does not enroll in Medicare | Yes — subsidy can continue while otherwise eligible |
Would have to pay for Part A, enrolls in Medicare anyway | No — enrolled Medicare ends subsidy eligibility |
Very low income | Check Medicaid / Medicare Savings Programs before choosing either path |
Additional Resources
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