Georgia Medicare Enrollment Periods: IEP, GEP, SEPs, and How to Enroll

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By Brevy Care Team · Last verified May 13, 2026

Medicare enrollment is one of the most consequential federal benefits decisions a Georgia senior will make, and the timing of that enrollment determines whether the beneficiary pays standard premiums, faces late enrollment penalties that last for life, or finds coverage delayed for months. The federal framework under Section 1837 of the Social Security Act (42 USC 1395p) and 42 CFR Part 407 establishes a structured system of enrollment windows: the Initial Enrollment Period (IEP) at age 65 or upon disability eligibility, the General Enrollment Period (GEP) for those who missed their first chance, a series of Special Enrollment Periods (SEPs) for life circumstances like losing employer coverage or being affected by a federal disaster, and the Annual Election Period (AEP) for Medicare Advantage and Part D plan changes. Each window has its own start date, duration, coverage effective date, and penalty implications.

Federal Authority: Section 1837 of the Social Security Act (42 USC 1395p) and 42 CFR Part 407

Coverage Pathways: Initial Enrollment Period (7 months around 65th birthday); General Enrollment Period (January 1 through March 31); Special Enrollment Periods (GHP, Exceptional Conditions, Equitable Relief, Termination of Medicaid)

BENES Act 2020: GEP coverage now starts the month after enrollment (was July 1 prior to January 2023)

Exceptional Conditions SEP (effective 2023): 42 CFR 407.23 created new SEP categories for Medicaid loss, employer misinformation, formerly incarcerated, federal disasters, and other exceptional conditions

Georgia Resources: Social Security Administration 1-800-772-1213; GeorgiaCares (SHIP) 1-866-552-4464; Medicare 1-800-MEDICARE :::

::: callout Key Takeaways for Georgia Medicare Enrollment

• The IEP is a 7-month window beginning 3 months before the month of your 65th birthday and ending 3 months after. Use it to enroll without penalty.
• The BENES Act 2020 modernized GEP coverage so coverage now starts the month after enrollment (was July 1 prior to January 2023).
• The Group Health Plan SEP under Section 1838(g) gives you 8 months after your active employment ends — not after COBRA ends — to enroll in Part B without penalty.
• COBRA is the most common LEP trap. COBRA does NOT count as current employment. Enroll in Part B within 8 months of active employment ending.
• GeorgiaCares SHIP at 1-866-552-4464 provides free Medicare counseling and enrollment help across all Georgia counties. :::

In 2026 the rules look different than they did three years ago. The BENES Act of 2020 (PL 116-260 Division CC Title I) eliminated the prior delay that pushed General Enrollment Period coverage to July 1 of each year, and now GEP coverage starts the first day of the month after enrollment. The 2023 Exceptional Conditions Special Enrollment Period regulation (42 CFR 407.23, finalized at 88 Fed. Reg. 1810) created entirely new SEP categories for retroactive Medicaid loss, employer misinformation, formerly incarcerated individuals, federal disaster declarations, and other exceptional conditions. Georgia seniors affected by Hurricane Helene in 2024 used this regulation to avoid late enrollment penalties when storm damage made timely enrollment impossible.

This guide walks Georgia families through every enrollment pathway: the seven-month IEP window structured around the 65th birthday, the three-month GEP from January through March each year, the eight-month Group Health Plan SEP under Section 1838(g) that protects beneficiaries retiring from large-employer coverage, the new Exceptional Conditions SEP categories effective 2023, the Equitable Relief process under Section 1837(h) when federal employees provide incorrect information, the auto-enrollment process for those receiving Social Security retirement benefits or 24 months of SSDI, the Medicare Advantage Annual Election Period October 15 through December 7 and the MA Open Enrollment Period January 1 through March 31, the Part D enrollment periods including the quarterly SEP for Low Income Subsidy recipients, and the coordination between Marketplace coverage and Medicare eligibility. We close with six worked examples, fifteen common enrollment mistakes, a comprehensive FAQ, and a contact list for Georgia families navigating these decisions.

The Federal Framework: Section 1837 of the Social Security Act

The statutory authority for Medicare Part A and Part B enrollment timing is Section 1837 of the Social Security Act, codified at 42 USC 1395p. This section was enacted as part of the original Medicare program in 1965 under Public Law 89-97 and has been amended multiple times. The implementing regulations are at 42 CFR Part 407, with detailed subsections covering each enrollment pathway.

Section 1837 establishes three primary enrollment periods for Part B: the Initial Enrollment Period under Section 1837(d), the General Enrollment Period under Section 1837(e), and Special Enrollment Periods under Section 1837(i). The companion Section 1838 (42 USC 1395q) governs coverage effective dates, including the Group Health Plan SEP under Section 1838(g) that allows beneficiaries with current employment coverage to delay Part B enrollment without penalty.

Section 1837(h) provides an equitable relief authority allowing Social Security to grant enrollment relief when federal employee error caused a beneficiary to miss an enrollment opportunity. This is a discretionary remedy and requires documentation of the federal error.

For Medicare Advantage and Part D, the framework is different. Section 1851 SSA governs MA enrollment with Annual Election Period and MA Open Enrollment Period rules, and Section 1860D-1 SSA governs Part D enrollment with similar but distinct timing.

The 2020 BENES Act was the most significant enrollment reform in two decades, modernizing the system effective January 2023 to eliminate coverage delays and provide for new types of SEPs. The 2023 Exceptional Conditions SEP regulation at 42 CFR 407.23 then implemented the BENES Act's SEP expansion authority by creating five new categories of SEP eligibility.

Initial Enrollment Period (IEP): The 7-Month Window Around Age 65

The Initial Enrollment Period is the foundation of Medicare enrollment timing. Under Section 1837(d) of the Social Security Act and 42 CFR 407.14, the IEP is a seven-month window structured around the month a beneficiary turns 65 or, for those entitled to Medicare due to disability, around the 25th month of Social Security Disability Insurance cash benefits.

Structure of the 7-Month IEP

The IEP begins three months before the month of the beneficiary's 65th birthday, includes the birthday month itself, and ends three months after the birthday month. The total window is seven months.

For example, a Georgia senior with a birthday on October 15, 2025 has an IEP that:

• Begins July 1, 2025 (3 months before October)
• Includes July, August, September (3 months before)
• Includes October (birthday month)
• Includes November, December, January 2026 (3 months after)
• Ends January 31, 2026

Coverage Effective Dates

Under the BENES Act 2020, coverage effective dates depend on when within the IEP the beneficiary enrolls:

• Enrollment during the 3 months before birthday month: Coverage starts the first day of the birthday month
• Enrollment during the birthday month: Coverage starts the first day of the month after birthday month
• Enrollment during the 3 months after birthday month: Coverage starts the first day of the month after enrollment

This is a meaningful change from the pre-BENES rule. Previously, enrollment during the 3 months after birthday month resulted in a 2-3 month coverage delay. Under the BENES Act effective January 2023, coverage now starts the month after enrollment, eliminating most coverage gaps.

Who Gets Auto-Enrolled

Beneficiaries already receiving Social Security retirement benefits at age 65 are automatically enrolled in both Part A and Part B. The Social Security Administration sends a Medicare card approximately three months before the 65th birthday, and Part B premiums are automatically deducted from the Social Security benefit beginning at the birthday month.

Beneficiaries receiving Social Security Disability Insurance are automatically enrolled in Medicare at the 25th month of SSDI cash benefits, regardless of age. The auto-enrollment letter and Medicare card arrive approximately three months before month 25.

Beneficiaries with ALS (amyotrophic lateral sclerosis) are auto-enrolled immediately upon SSDI entitlement without the 24-month wait, per Section 226(h) SSA. Beneficiaries with end-stage renal disease have specialized enrollment timing under Section 226A SSA, with coverage beginning the fourth month of dialysis (or earlier with home dialysis training or kidney transplant).

Manual Enrollment Required

Beneficiaries who have delayed claiming Social Security retirement benefits must manually enroll in Medicare. This is increasingly common as more Americans delay Social Security to age 67 or 70 for higher monthly benefits. These beneficiaries must take affirmative action during the IEP to enroll.

Most workers still active at age 65 with employer health coverage also fall into the manual enrollment category. They may choose to delay Part B enrollment under the Group Health Plan SEP rules described below, but they must affirmatively coordinate that timing.

How to Enroll

Three primary enrollment pathways exist:

• Online at ssa.gov/medicare (fastest, available 24/7)
• Phone via Social Security 1-800-772-1213 (Monday-Friday 8 AM to 7 PM)
• In person at a local Social Security field office in Georgia (field offices across the state)

Form CMS-40B is used for Part B enrollment. The form can be downloaded from cms.gov or completed online via the Social Security website.

General Enrollment Period (GEP): The Recovery Window

The General Enrollment Period is the backup window for beneficiaries who missed their IEP and do not qualify for a Special Enrollment Period. Under Section 1837(e) SSA and 42 CFR 407.15, the GEP runs from January 1 through March 31 of each calendar year.

Coverage Effective Date Under BENES Act 2020

The BENES Act made the most significant change in this area. Prior to January 2023, GEP enrollment resulted in coverage delayed until July 1 of the enrollment year, regardless of when during the January-March window the beneficiary enrolled. This created coverage gaps of three to six months and was widely criticized as harmful to vulnerable seniors.

Effective January 2023, GEP coverage now starts the first day of the month after enrollment:

• January enrollment → February 1 coverage start
• February enrollment → March 1 coverage start
• March enrollment → April 1 coverage start

This change eliminated the most punitive aspect of the prior GEP rules and brought GEP coverage timing in line with IEP coverage timing.

Late Enrollment Penalties

GEP enrollment typically triggers a Part B late enrollment penalty under Section 1839(b) SSA. The penalty is 10 percent of the standard Part B premium for each 12 months of delay between the IEP and the GEP enrollment. The penalty is permanent and applies for the beneficiary's lifetime.

For example, a beneficiary who missed her IEP that ended in October 2024 and enrolls during the GEP in March 2026 has approximately 17 months of delay. The penalty calculation rounds down to full 12-month periods, so 17 months = 1 complete 12-month period = 10 percent LEP.

At the 2026 standard Part B premium of $202.90 per month, a 10 percent LEP adds $20.29 per month, for a total monthly premium of $223.19. Over 20 years of Medicare coverage, this LEP would cost approximately $4,870.

Coordination with Medicaid Buy-In

Beneficiaries who qualify for Medicaid Buy-In through QMB, SLMB, or QI under Section 1843 SSA and Section 1905(p) SSA have their Part B premium paid by Georgia Medicaid. For full-Medicaid plus QMB enrollees, the late enrollment penalty is also paid by Medicaid, effectively waiving the penalty. For SLMB and QI enrollees, only the standard premium is paid, and the beneficiary remains responsible for any LEP. This coordination makes Medicaid Buy-In enrollment particularly valuable for low-income Georgia seniors who delayed Part B enrollment due to misunderstanding or financial hardship.

Group Health Plan Special Enrollment Period (GHP SEP)

The most commonly used SEP is the Group Health Plan SEP under Section 1838(g) SSA. This SEP allows beneficiaries with current employment-based health coverage to delay Part B enrollment without incurring a late enrollment penalty.

Structure of the GHP SEP

The GHP SEP is an eight-month window beginning the first month after either active employment ends OR group health plan coverage based on current employment ends, whichever comes first. This is the critical timing rule that creates the COBRA trap discussed below.

Requirements

To qualify for the GHP SEP, the beneficiary must satisfy three conditions:

1. The beneficiary or the beneficiary's spouse must have had current employment status with an employer providing the group health plan
2. The group health plan coverage must have been based on that current employment, not retiree status
3. The beneficiary must enroll in Part B within the eight-month window

The Medicare Secondary Payer rules under Section 1862(b)(1)(A) and 1862(b)(1)(B) interact with these requirements. For working aged beneficiaries (age 65+), the group health plan must be from an employer with 20 or more employees for the GHP to be primary payer. For disabled beneficiaries under 65, the employer must have 100 or more employees.

The COBRA Trap

COBRA continuation coverage does NOT count as current employment-based coverage for GHP SEP purposes. This is the single most common cause of Part B late enrollment penalties in America.

When a beneficiary's active employment ends, the GHP SEP clock starts immediately, even if the beneficiary elects COBRA continuation. The eight-month SEP window runs from the month after active employment ends, not from the month after COBRA ends. A beneficiary who elects 18 months of COBRA and then enrolls in Part B is approximately 18 months past the start of the GHP SEP and faces a 10 percent LEP for life.

Retiree Coverage Does Not Count

Retiree health coverage from a former employer also does NOT count as current employment for GHP SEP purposes. Beneficiaries who retire and rely on retiree coverage without enrolling in Part B face the same penalty risk as COBRA-only beneficiaries.

The general rule: only health coverage based on actively employed status (the beneficiary or spouse currently working for the employer) qualifies for the GHP SEP protection.

Examples of GHP SEP Use

• Working aged employee retires at 67: Large-employer GHP coverage ends December 31, 2025. GHP SEP begins January 2026 and runs through August 2026. Employee enrolls in Part B February 2026 with no LEP.
• Spouse of working aged employee: Spouse covered under employee's GHP loses coverage when employee's active employment ends. Same 8-month SEP applies.
• Disabled beneficiary under 65 with current spousal employment: Beneficiary covered under spouse's large-employer GHP. Spouse retires at 65. 8-month SEP for the disabled beneficiary begins month after spouse's active employment ends.

Exceptional Conditions SEP (Effective 2023)

The 2023 Exceptional Conditions SEP regulation at 42 CFR 407.23 created entirely new SEP categories under the authority of Section 1837(i)(4) SSA. The final rule was published at 88 Fed. Reg. 1810 on January 10, 2023 and took effect January 1, 2023. This represents the most significant expansion of Medicare enrollment flexibility in decades.

Five Categories of Exceptional Conditions

The regulation establishes five categories of exceptional conditions that trigger SEP eligibility:

Category 1 (Termination of Medicaid, 42 CFR 407.23(b)(1)): Beneficiaries whose Medicaid coverage is terminated retroactively or who lose Medicaid eligibility have a six-month SEP beginning the month they receive notice of Medicaid termination. Coverage can be retroactive up to six months. This category was particularly important during the 2023-2024 Medicaid redetermination ("unwinding") period when millions of Americans lost Medicaid after the public health emergency ended.

Category 2 (Misrepresentation by Employer or Insurance Broker, 42 CFR 407.23(b)(2)): When an employer or broker materially misrepresents Medicare or group health plan coverage information, the beneficiary has a six-month SEP from when the misrepresentation is discovered. Documentation of the misrepresentation is required.

Category 3 (Formerly Incarcerated Individuals, 42 CFR 407.23(b)(3)): Individuals released from incarceration have a 12-month SEP from the month after release. This addresses a long-standing barrier for the formerly incarcerated who often lose Medicare enrollment opportunities while in custody.

Category 4 (Federal, State, or Local Disaster Declarations, 42 CFR 407.23(b)(4)): Beneficiaries affected by FEMA-declared or governor-declared disasters have an SEP to enroll. This category includes hurricanes, wildfires, severe storms, and public health emergencies. Georgia beneficiaries affected by Hurricane Helene in 2024 used this category extensively.

Category 5 (Other Exceptional Conditions, 42 CFR 407.23(b)(5)): A catch-all category determined by CMS on a case-by-case basis. Examples include cognitive impairment that prevented timely enrollment, severe medical conditions during the IEP, and other circumstances that materially impacted the beneficiary's ability to enroll.

Application Process

The beneficiary files an application with the Social Security Administration documenting the exceptional condition. Documentation requirements vary by category but typically include:

• For Medicaid loss: termination notice from Georgia DCH or DFCS
• For employer misrepresentation: written communication showing the misrepresentation
• For disaster: FEMA disaster declaration number and documentation of impact
• For incarceration: release documentation from corrections authority

SSA reviews the application and approves or denies. Appeal rights apply if the application is denied.

Equitable Relief Under Section 1837(h)

Section 1837(h) SSA authorizes Social Security to grant equitable relief from Part B enrollment penalties or coverage delays when a federal employee's error caused the beneficiary to miss an enrollment opportunity.

When Equitable Relief Is Available

Equitable relief applies when:

• A federal employee (SSA, CMS, Medicare) provided incorrect information about enrollment timing
• A federal notice contained material errors
• A federal agency failed to inform the beneficiary of enrollment options
• The beneficiary reasonably relied on the federal misinformation to her detriment

Examples

• SSA provided incorrect IEP dates and beneficiary enrolled after IEP ended
• Medicare provided incorrect information about creditable coverage status
• Federal employee at SSA office misadvised beneficiary that she did not need Part B because of VA coverage
• SSA failed to send required enrollment notices before age 65

Process

The beneficiary files a written request with Social Security documenting:

• The specific federal error
• How the beneficiary relied on the misinformation
• What enrollment opportunity was missed
• The harm caused (LEP or coverage delay)

SSA makes a discretionary determination. Approved relief typically waives the LEP and provides retroactive coverage. If denied, the beneficiary has appeal rights to a Social Security administrative law judge.

SSDI Auto-Enrollment and Disability Medicare

Beneficiaries entitled to Medicare based on disability (rather than age 65) have specialized enrollment rules under Section 226 SSA.

The 24-Month Waiting Period

After receiving Social Security Disability Insurance cash benefits for 24 months, the beneficiary is automatically enrolled in Medicare Part A and Part B effective month 25. The auto-enrollment letter arrives approximately three months before month 25.

ALS Exception

Beneficiaries with amyotrophic lateral sclerosis receive immediate Medicare entitlement under Section 226(h) SSA without the 24-month wait. Coverage begins the first month of SSDI cash benefits.

ESRD Enrollment

Beneficiaries with end-stage renal disease receive Medicare under Section 226A SSA. The coverage begins:

• The fourth month of dialysis (standard 3-month waiting period)
• The first month if home dialysis training begins
• The month of kidney transplant

ESRD beneficiaries have a 30-month coordination period under Section 1862(b)(1)(C) during which group health plan coverage is primary payer.

Opting Out of Part B at Age 65 Conversion

Disabled beneficiaries who reach age 65 transition from disability-based Medicare to age-based Medicare. The IEP at age 65 still applies, and beneficiaries who declined Part B previously can use this opportunity to enroll without LEP.

Medicare Advantage and Part D Enrollment Periods

Medicare Advantage (Part C) and Part D have their own enrollment period framework under Section 1851 SSA and Section 1860D-1 SSA. These periods are distinct from the Part A and Part B enrollment periods discussed above.

Annual Election Period (AEP)

The AEP runs October 15 through December 7 each year under Section 1851(e)(3). During the AEP, beneficiaries can:

• Switch from one Medicare Advantage plan to another
• Switch from Medicare Advantage back to Original Medicare
• Switch from Original Medicare to Medicare Advantage
• Enroll in, change, or drop a Part D plan

Coverage from AEP elections is effective January 1 of the following year.

Medicare Advantage Open Enrollment Period (MA-OEP)

The MA-OEP runs January 1 through March 31 each year under Section 1851(e)(2)(C). This period is available only to those already enrolled in Medicare Advantage at the start of the year and allows one of the following changes:

• Switch from one MA plan to another
• Switch from MA back to Original Medicare with a Part D plan

Note that MA-OEP does NOT allow switching from Original Medicare to MA. Beneficiaries in Original Medicare can only switch to MA during AEP.

Initial Coverage Election Period (ICEP)

The ICEP for Medicare Advantage aligns with the IEP for Original Medicare. New Medicare beneficiaries can enroll in an MA plan during their 7-month IEP.

Special Enrollment Periods for MA and Part D

42 CFR 422.62 (for MA) and 42 CFR 423.38 (for Part D) establish numerous SEPs:

• Move out of plan service area
• Lose creditable Part D coverage involuntarily
• Qualify for Extra Help / Part D Low Income Subsidy
• Qualify for QMB/SLMB/QI
• 5-star plan SEP (December 8 through November 30 each year) for switching to a 5-star rated plan
• Plan termination by CMS
• Exceptional circumstances (case-by-case CMS determination)

Part D LIS Quarterly SEP

Beneficiaries eligible for Part D Extra Help (Low Income Subsidy) historically had a monthly SEP. Full-benefit dual-eligibles generally retain more frequent SEP access than other LIS-eligible beneficiaries.

Marketplace-to-Medicare Coordination

The transition from ACA Marketplace coverage to Medicare is a common source of confusion for Georgia families approaching age 65.

Termination Timing

Marketplace coverage should be terminated at the start of Medicare coverage. Beneficiaries who continue Marketplace coverage after becoming Medicare-eligible:

• Lose eligibility for premium tax credits (Marketplace subsidies)
• May face tax credit recapture at year-end filing
• Pay full unsubsidized Marketplace premiums

Best Practice

Most beneficiaries terminate Marketplace coverage effective the last day of the month before Medicare begins. For example, a beneficiary with March 1, 2026 Medicare start date would terminate Marketplace coverage effective February 28, 2026.

Cost Comparison

The cost difference between Marketplace and Medicare can be significant. A 64-year-old in Atlanta might pay $50/month for a silver Marketplace plan with $400/month in premium tax credits. At Medicare, the same person would pay $202.90 for Part B plus Part D premium and supplemental coverage costs (Medigap or MA), often totaling $350-$450/month before any supplemental help.

Georgia families approaching 65 should explore Medicare Savings Programs (QMB, SLMB, QI) and Part D Extra Help to mitigate this cost transition.

Coordination with Georgia Medicaid

Termination of Medicaid SEP

Under 42 CFR 407.23(b)(1), Georgia seniors who lose Medicaid coverage have a 6-month SEP to enroll in Medicare without LEP. This was particularly important during the 2023-2024 Medicaid redetermination period when many Georgia seniors temporarily lost Medicaid eligibility and needed to enroll in Medicare.

Buy-In Coordination

Section 1843 SSA authorizes Georgia Medicaid to pay Medicare Part A and Part B premiums for beneficiaries enrolled in Medicaid Buy-In programs (QMB, SLMB, QI). For full-Medicaid plus QMB enrollees, the LEP is also paid by Medicaid, effectively waiving the penalty.

Georgia DCH automatically initiates Buy-In coordination when a beneficiary qualifies for QMB, SLMB, or QI. The Buy-In typically begins the month after eligibility determination, with retroactive coverage for prior months when applicable.

Dual-Eligible Special Enrollment

Dual-eligibles (Medicare + Medicaid) have monthly or quarterly SEPs for Part D and MA enrollment changes, providing flexibility to optimize plan selection based on changing health needs and plan offerings.

Georgia Resources for Enrollment Help

GeorgiaCares SHIP

GeorgiaCares is Georgia's State Health Insurance Assistance Program (SHIP). The program provides free, unbiased Medicare counseling through county-level counselors statewide. Services include:

• IEP, GEP, and SEP eligibility analysis
• Plan comparison (Medicare Advantage, Medigap, Part D)
• Enrollment assistance
• Appeals and grievance help
• Medicare Savings Program screening
• LIS / Extra Help screening

Contact: 1-866-552-4464

Social Security Field Offices

Social Security operates field offices across Georgia. Field offices process:

• Initial Part A and Part B enrollment (IEP, GEP, SEP)
• Equitable Relief requests under Section 1837(h)
• Exceptional Conditions SEP applications under 42 CFR 407.23

Locate the nearest office: ssa.gov/locator or 1-800-772-1213.

DCH and DFCS

The Georgia Department of Community Health (DCH) administers Medicaid and the Medicare Buy-In program. The Division of Family and Children Services (DFCS) processes Medicaid eligibility. Contact DCH at 1-866-211-0950 or DFCS at 1-877-423-4746.

Worked Examples

Margaret 64 Atlanta: IEP Enrollment

Margaret lives in Atlanta and will turn 65 on October 15, 2025. She retired at 62 and has been on her husband's small-employer health plan (8 employees). Under Medicare Secondary Payer rules, her husband's small-employer plan is secondary to Medicare once she becomes eligible, so she cannot delay Part B enrollment through the Group Health Plan SEP.

Margaret reviews her IEP timing:

• IEP begins July 1, 2025
• IEP includes July, August, September (3 months before birthday)
• Includes October (birthday month)
• Includes November, December, January 2026 (3 months after)
• IEP ends January 31, 2026

Margaret decides to enroll early to ensure coverage begins her birthday month. She visits ssa.gov/medicare in August 2025 and completes the online Medicare application. She enrolls in both Part A and Part B. Two weeks later she receives her Medicare card with effective date October 1, 2025.

Her monthly costs:

• Part B premium: $202.90/month (2026)
• Part D plan: $34/month
• Medigap Plan G: $145/month
• Total: approximately $382/month

She does not face any LEP because she enrolled within her IEP. She also signs up with Atlanta's GeorgiaCares counselor for help comparing Part D plans and Medigap options.

Robert 67 Savannah: Missed IEP and GEP Recovery

Robert lives in Savannah and turned 65 in April 2024. He was working part-time at a small business (10 employees) at the time and assumed his employer health coverage was sufficient. His employer told him he did not need Medicare because of the company plan.

Eighteen months later, Robert's employer was acquired and his health benefits were terminated. He learned that his small-employer coverage had been secondary to Medicare all along, meaning he had effectively had no primary coverage for 18 months. Worse, he had missed his IEP.

Robert visits GeorgiaCares in February 2026. The counselor explains:

• His IEP ended in October 2024 (3 months after April birthday)
• He missed the IEP entirely
• He must use the GEP (January 1 - March 31, 2026)
• He may also qualify for Exceptional Conditions SEP under 42 CFR 407.23(b)(2) due to employer misrepresentation

The counselor recommends filing both a GEP application and an Exceptional Conditions SEP application simultaneously, with documentation of the employer's incorrect coverage advice.

Robert files Form CMS-40B on March 15, 2026. Under the BENES Act, his coverage begins April 1, 2026. His Part B LEP is initially calculated as 10 percent (17 months delay rounded down to 12 months).

Robert also submits documentation showing his employer's written assertion that he did not need Medicare. SSA approves his Exceptional Conditions SEP under 42 CFR 407.23(b)(2), waiving the LEP. His final Part B premium is $202.90/month with no penalty.

Linda 66 Macon: GHP SEP From 500-Employee Firm

Linda lives in Macon and is 66 years old. She has been working full-time at a 500-employee firm with comprehensive group health coverage. Under Section 1862(b)(1)(A) SSA, her employer-based coverage is primary to Medicare because the employer has 20 or more employees and she is in current employment.

Linda did NOT enroll in Part B at age 65 because her GHP coverage was primary and she did not want to pay two premiums. This was a valid choice as long as she maintained current employment.

Linda decides to retire effective December 31, 2025. Her active employment ends that day. Under Section 1838(g) SSA, her 8-month Group Health Plan SEP begins January 2026 and runs through August 2026.

Linda files Form CMS-40B with documentation of her active employment dates (CMS-L564 from her employer) on February 10, 2026. SSA processes the application and her Part B coverage begins March 1, 2026. No LEP applies because she enrolled during her GHP SEP.

She also enrolls in a Part D plan during her Part D Initial Enrollment Period (which aligns with her Part B enrollment trigger) and selects Medigap Plan G.

Her monthly costs:

• Part B premium: $202.90
• Part D plan: $42
• Medigap Plan G: $158
• Total: approximately $403/month

Linda also notes that she could have continued COBRA from her former employer for up to 18 months, but COBRA does NOT count as current employment for GHP SEP purposes. If she had elected COBRA and delayed Part B enrollment beyond 8 months, she would have faced a permanent LEP.

Charles 50 Augusta: SSDI Month 25 Auto-Enrollment

Charles is 50 years old and lives in Augusta. He developed a chronic condition in 2023 that prevented him from working. He applied for Social Security Disability Insurance and was approved with disability onset March 2023. Due to the standard 5-month SSDI waiting period, his cash benefits began September 2023.

Under Section 226 SSA, Charles is entitled to Medicare after 24 months of SSDI cash benefits. Month 25 of his SSDI = September 2025.

In approximately June 2025, Charles receives an auto-enrollment letter from Social Security explaining that his Medicare Part A and Part B will begin September 1, 2025. The letter includes a Medicare card and instructions for declining Part B if he has other creditable coverage.

Charles has no other coverage, so he keeps both Part A and Part B. His Part B premium ($202.90/month in 2026) is automatically deducted from his SSDI benefit.

Charles also explores Medicaid options because his SSDI income is modest. He qualifies for QMB through Georgia DCH (income under 100 percent FPL plus $20 disregard). Once approved, Georgia Medicaid pays his Part B premium through the Section 1843 Buy-In, eliminating his out-of-pocket Medicare cost. He also qualifies for Part D Low Income Subsidy, reducing his prescription costs to $0-$12 per prescription.

Patricia 64 Columbus: Marketplace-to-Medicare Transition

Patricia lives in Columbus and is currently 64 years old. She has been enrolled in an ACA Marketplace silver plan for the past five years. Her monthly premium is $50 after a $400/month premium tax credit. She will turn 65 in March 2026.

Patricia's IEP:

• Begins December 1, 2025 (3 months before March birthday)
• Includes December, January, February (3 months before)
• Includes March (birthday month)
• Includes April, May, June (3 months after)
• Ends June 30, 2026

Patricia enrolls in Medicare Part A and Part B in January 2026 (during the 3-months-before window). Her Medicare coverage begins March 1, 2026 (her birthday month).

She terminates her Marketplace coverage effective February 28, 2026. She specifically logs into Healthcare.gov and ends her coverage to avoid tax credit recapture issues.

Patricia's costs jump significantly:

• Marketplace net premium: $50/month
• Medicare costs: Part B $202.90 + Part D $32 + Medigap Plan G $148 = $382.90/month
• Increase: approximately $333/month

Patricia is concerned about the cost increase. She visits GeorgiaCares and learns that with her modest retirement income, she may qualify for a Medicare Savings Program. The counselor screens her income (Social Security retirement plus small annuity = $1,520/month). At 124 percent FPL, she qualifies for SLMB (Specified Low Income Medicare Beneficiary) under Section 1905(p)(3)(A)(ii).

With SLMB enrollment through Georgia Medicaid:

• Part B premium $202.90 paid by Medicaid
• Patricia's out-of-pocket: $32 Part D + $148 Medigap = $180/month
• Approximate parity with her former Marketplace costs

Patricia files the SLMB application with DFCS and is approved effective March 2026.

Henry 73 Athens: Exceptional Conditions SEP After Hurricane Helene

Henry lives in Athens-Clarke County and is 73 years old. He missed his original IEP at age 65 due to a complicated cancer treatment that consumed his attention during 2017-2018. He enrolled during the GEP in 2019 with a 30 percent Part B LEP (3 years of delay).

In September 2024, Hurricane Helene caused severe damage to Henry's home in Athens-Clarke County. His home was uninhabitable for four months. He was displaced to a relative's home in another county. His mail was disrupted.

In February 2025, Henry realizes he never enrolled in a Part D plan after his 2019 Part B enrollment. He had been paying out of pocket for all medications. He is now facing a Part D LEP for years of delay.

Henry attempts to use the GEP for Part D enrollment but learns that the regular GEP for Part D is the AEP (October 15 - December 7). He missed the 2024 AEP due to the disaster.

A GeorgiaCares counselor reviews Henry's situation and identifies the Exceptional Conditions SEP under 42 CFR 407.23(b)(4) for federal disaster declarations. Athens-Clarke County was included in the FEMA disaster declaration for Hurricane Helene.

Henry files an Exceptional Conditions SEP application with Social Security in March 2025. He documents:

• FEMA disaster declaration number for Hurricane Helene
• His home's damage and uninhabitable status
• His four-month displacement
• His inability to address Medicare matters during this period

SSA approves the SEP. Henry enrolls in a Part D plan effective April 1, 2025. The Exceptional Conditions SEP waives the Part D LEP he would otherwise have faced. He pays only the standard Part D premium going forward.

15 Common Enrollment Mistakes

1. Assuming Medicare auto-enrolls at 65 for everyone. Only beneficiaries already collecting Social Security retirement or SSDI are auto-enrolled. Workers who delay Social Security must manually enroll.

2. Confusing IEP with AEP. The IEP is for new Medicare beneficiaries enrolling in Part A and Part B. The AEP (October 15-December 7) is for existing Medicare beneficiaries making Medicare Advantage and Part D plan changes.

3. Believing COBRA counts as current employment for GHP SEP. COBRA does NOT count. The 8-month SEP clock starts when active employment ends, regardless of COBRA continuation.

4. Assuming retiree coverage qualifies for GHP SEP. Retiree coverage does NOT count as current employment. Only active employee coverage qualifies.

5. Missing the GEP because of GHP SEP timing confusion. If you don't qualify for GHP SEP (e.g., your employer has fewer than 20 employees), you must use IEP or GEP. Don't wait for the GHP SEP window to open if it never will.

6. Failing to terminate Marketplace coverage when Medicare-eligible. Continued Marketplace enrollment after Medicare eligibility can trigger premium tax credit recapture at year-end tax filing.

7. Not requesting Equitable Relief when federal error caused enrollment failure. Section 1837(h) provides discretionary relief for federal employee errors. File a written request with documentation.

8. Missing the 8-month GHP SEP deadline. The SEP is calendar-based, not based on when the beneficiary realizes she should have enrolled. Track the deadline carefully.

9. Not enrolling in Part D when LIS-eligible. LIS (Extra Help) eligibility under Section 1860D-14 SSA significantly reduces Part D costs. Many low-income Georgia seniors don't realize they qualify.

10. Confusing MA-OEP (January-March) with AEP (October-December). The MA-OEP allows MA enrollees one switch back to Original Medicare or to another MA plan. It does NOT allow switching from Original Medicare to MA.

11. Failing to use the Exceptional Conditions SEP when applicable. The 2023 regulation at 42 CFR 407.23 created new SEP categories for Medicaid loss, employer misrepresentation, formerly incarcerated, federal disasters, and other exceptional conditions. Many Georgia beneficiaries don't know about this option.

12. Not coordinating Buy-In with Medicaid enrollment. QMB enrollment triggers automatic Part B Buy-In under Section 1843, paying the Part B premium. Many beneficiaries don't apply for QMB because they don't realize the savings.

13. Assuming Part D LEP is the same as Part B LEP. Part B LEP is 10 percent per 12 months. Part D LEP is 1 percent per month (12 percent per year). They are calculated separately.

14. Missing the 4th-month coverage start for ESRD-based Medicare. ESRD beneficiaries should plan for the 3-month dialysis waiting period or use home dialysis training for earlier coverage.

15. Failing to enroll in Part B during GHP SEP because employer says coverage is creditable. Employer "creditable coverage" applies to Part D, not Part B. Part B has separate enrollment rules and the employer's creditable coverage statement is irrelevant.

Quick Reference

Initial Enrollment Period (IEP): 7 months around 65th birthday or month 25 of SSDI General Enrollment Period (GEP): January 1 - March 31 each year (coverage starts month after enrollment) Group Health Plan SEP: 8 months after active employment ends (not COBRA end) Annual Election Period (AEP) for MA and Part D: October 15 - December 7 MA Open Enrollment Period (MA-OEP): January 1 - March 31 (existing MA enrollees only) Exceptional Conditions SEP: 6 months (most categories) under 42 CFR 407.23 Equitable Relief: Discretionary, file with SSA documenting federal error Termination of Medicaid SEP: 6 months from notice of Medicaid termination Part B LEP: 10 percent per 12 months delay, permanent Part D LEP: 1 percent per month delay, permanent

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When does my Initial Enrollment Period begin and end?

Your IEP is a 7-month window that begins 3 months before the month of your 65th birthday and ends 3 months after the birthday month. For example, if your birthday is October 15, 2025, your IEP runs from July 1, 2025 through January 31, 2026. The IEP includes the 3 months before, the birthday month itself, and the 3 months after.

What happens if I enroll during different parts of the IEP?

Coverage start dates depend on when you enroll within the 7-month window. Enrollment during the 3 months before your birthday month means coverage starts the first day of your birthday month. Enrollment during the birthday month means coverage starts the first day of the next month. Enrollment during the 3 months after your birthday month means coverage starts the first day of the month after you enroll (this is the BENES Act 2020 change effective January 2023).

What is the General Enrollment Period?

The GEP runs from January 1 through March 31 each year. It is for beneficiaries who missed their IEP and do not qualify for a Special Enrollment Period. Under the BENES Act 2020, coverage now starts the first day of the month after enrollment (before January 2023, coverage was delayed until July 1).

What is the Group Health Plan Special Enrollment Period?

The GHP SEP under Section 1838(g) SSA is an 8-month window beginning the first month after your active employment ends OR your group health plan coverage based on current employment ends, whichever comes first. It allows you to enroll in Part B without a late enrollment penalty after retiring from a job with health coverage.

Does COBRA count as current employment for the GHP SEP?

No. COBRA continuation coverage does NOT count as current employment. The 8-month GHP SEP clock starts when your active employment ends, regardless of COBRA. This is the single most common cause of Part B late enrollment penalties.

Does retiree health coverage count as current employment?

No. Retiree coverage does NOT count as current employment for GHP SEP purposes. Only health coverage based on you or your spouse being currently employed by the employer qualifies.

What is the Exceptional Conditions SEP that started in 2023?

The Exceptional Conditions SEP at 42 CFR 407.23 is a new regulation effective January 1, 2023 that created five SEP categories: (1) termination of Medicaid, (2) employer or broker misrepresentation, (3) formerly incarcerated individuals, (4) federal/state/local disaster declarations, and (5) other exceptional conditions determined by CMS. Each category has documentation requirements and most provide a 6-month SEP window.

Can I use the disaster SEP for Hurricane Helene?

Yes, if you live in a Georgia county included in the FEMA disaster declaration for Hurricane Helene (September 2024). You can file an Exceptional Conditions SEP application under 42 CFR 407.23(b)(4) documenting the disaster impact on your ability to enroll.

What is Equitable Relief?

Equitable Relief under Section 1837(h) SSA is a discretionary remedy that Social Security can grant when a federal employee's error (incorrect information, missing notices, material errors) caused you to miss a Medicare enrollment opportunity. File a written request with SSA documenting the federal error and how you relied on it.

When am I auto-enrolled in Medicare?

You are auto-enrolled if you are already receiving Social Security retirement benefits at age 65, or after receiving SSDI cash benefits for 24 months (month 25 of SSDI). Beneficiaries with ALS are auto-enrolled immediately upon SSDI entitlement. Most other 65-year-olds must manually enroll in Medicare.

What is the Medicare Advantage Annual Election Period?

The MA AEP runs October 15 through December 7 each year. During AEP you can switch MA plans, switch from MA back to Original Medicare, switch from Original Medicare to MA, or change Part D plans. Coverage from AEP elections is effective January 1 of the following year.

What is the MA Open Enrollment Period (MA-OEP)?

The MA-OEP runs January 1 through March 31 each year and is available only to those already enrolled in Medicare Advantage at the start of the year. You can make one switch: to another MA plan, or back to Original Medicare with a Part D plan. You cannot switch from Original Medicare to MA during this period.

When can I switch Part D plans?

You can switch Part D plans during the AEP (October 15 - December 7) with coverage effective January 1. Special Enrollment Periods also allow plan changes for circumstances like moving, losing creditable coverage, qualifying for Extra Help, qualifying for Medicare Savings Programs, or 5-star plan SEPs.

What is the Termination of Medicaid SEP?

Under 42 CFR 407.23(b)(1), if your Medicaid coverage is terminated (including retroactive termination), you have a 6-month SEP to enroll in Medicare. Coverage can be retroactive up to 6 months. This was particularly important during the 2023-2024 Medicaid redetermination "unwinding" period.

How does Medicare coordinate with my Marketplace coverage?

Marketplace coverage should be terminated when your Medicare coverage begins. Continued Marketplace enrollment after Medicare eligibility means you lose premium tax credit eligibility and may face tax credit recapture at year-end tax filing. Terminate Marketplace coverage through Healthcare.gov effective the last day of the month before Medicare begins.

What is the Part B late enrollment penalty?

Section 1839(b) SSA imposes a 10 percent late enrollment penalty for each full 12-month period of delay between when you were first eligible for Part B and when you actually enrolled. The penalty is permanent and is added to your monthly Part B premium for life. At the 2026 standard premium of $202.90, a 10 percent LEP adds $20.29/month.

What is the Part D late enrollment penalty?

Section 1860D-13(b) imposes a 1 percent late enrollment penalty for each month of delay (12 percent per year) without creditable prescription coverage. The penalty is calculated based on the national base beneficiary premium and is permanent.

Does Medicaid pay my Part B premium?

Yes, if you qualify for QMB, SLMB, or QI under Section 1905(p) SSA, Georgia Medicaid pays your Part B premium through the Section 1843 Buy-In. For full-Medicaid plus QMB enrollees, the LEP is also paid by Medicaid, effectively waiving the penalty.

How do I enroll in Medicare?

Three options: (1) online at ssa.gov/medicare, (2) phone at SSA 1-800-772-1213, or (3) in person at a local Social Security field office in Georgia. Form CMS-40B is used for Part B enrollment. The online application is fastest and available 24/7.

What documentation do I need to enroll?

Standard documentation includes proof of identity, proof of age (birth certificate), Social Security number, and (for the GHP SEP) Form CMS-L564 completed by your employer documenting your active employment dates and group health plan coverage. For Exceptional Conditions SEP, additional documentation specific to your category (disaster declaration, Medicaid termination notice, etc.).

Can I delay Part A enrollment?

Most beneficiaries should NOT delay Part A enrollment because Part A is premium-free for those with 40+ quarters of Medicare-covered employment (or spouse with same). If you are receiving Social Security at 65, you cannot decline Part A without giving up Social Security benefits. Delaying Part A while contributing to an HSA is possible but complicated.

Should I enroll in Part B if I have VA coverage?

Veterans should generally enroll in Part B during their IEP. VA coverage does not protect from Part B late enrollment penalty if you delay Part B beyond IEP, and VA coverage does not provide care from non-VA providers. Enrolling in Part B at 65 gives you flexibility to use either system. Consult GeorgiaCares for personalized advice.

What if my employer told me I don't need Part B?

If your employer materially misrepresented your need for Part B, you may qualify for the Exceptional Conditions SEP under 42 CFR 407.23(b)(2) (misrepresentation by employer or insurance broker). You also may qualify for Equitable Relief if federal employees were involved. Document the misrepresentation in writing.

How do I find a Social Security office in Georgia?

Use the SSA office locator at ssa.gov/locator or call 1-800-772-1213. Georgia has field offices statewide, with concentrations in Atlanta, Savannah, Macon, Augusta, Columbus, and Athens. Most services can also be completed online or by phone.

Where can I get free Medicare counseling in Georgia?

GeorgiaCares is the state's SHIP (State Health Insurance Assistance Program). Call 1-866-552-4464 to connect with a free, unbiased Medicare counselor in your county. GeorgiaCares operates county-level counselors statewide and can help with enrollment, plan comparison, appeals, and Medicare Savings Program screening. :::

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Federal Medicare Enrollment

• Medicare 1-800-MEDICARE (1-800-633-4227)
• Social Security Administration 1-800-772-1213
• SSA Office Locator: ssa.gov/locator
• Medicare.gov enrollment portal

Georgia State Resources

• DCH Medicaid Member Services 1-866-211-0950
• DCH Provider Services 1-800-766-4456
• DFCS Customer Service 1-877-423-4746
• GeorgiaCares SHIP 1-866-552-4464

Counseling and Advocacy

• Medicare Rights Center 1-800-333-4114
• Center for Medicare Advocacy 1-860-456-7790
• Justice in Aging 202-289-6976
• AARP Georgia 1-866-295-7283

Legal Help

• Atlanta Legal Aid Senior Citizens Law Project 404-377-0701
• Georgia Legal Services Program 1-800-498-9469
• 211 Georgia (general resources)
• Eldercare Locator 1-800-677-1116

Plan Information

• Georgia Office of Insurance Commissioner 1-800-656-2298
• CMS Region IV Office (Atlanta)
• Palmetto GBA Georgia MAC 1-855-696-0705 :::

This guide is part of Brevy's comprehensive Georgia Medicaid and Medicare resource library. For more on coordinated benefits, see our deep dives on QMB, SLMB, QI, the Medicare Buy-In, Medicare Secondary Payer rules, and the Part B late enrollment penalty. Find personalized help navigating Georgia Medicare enrollment at brevy.com.

Disclaimer: This article provides educational information about Medicare enrollment periods and Georgia's coordinated Medicaid programs. It is not legal, financial, or medical advice. Federal and state rules change frequently, and individual circumstances vary. For specific guidance, contact Social Security, GeorgiaCares SHIP, or a qualified elder law attorney. Last verified: May 2026.