Mandatory Medicare Enrollment at age 65

In January 2025 MassHealth described its plans to implement a cost-savings initiative to require older adults on MassHealth Standard to enroll in Medicare as a condition of maintaining their MassHealth coverage in FY 2026. This initiative will affect approximately 10,800 older adults, three-fourths of whom are non-citizens. This initiative couldn’t come at a worse time given the staffing cuts and delays at SSA offices and the many negative actions of the federal government targeting the immigrant community and spreading fear. Nonetheless MassHealth is moving forward with it.

Yesterday on June 16, 2025, MassHealth released Eligibility Operation Memo 25-10 entitled Mandatory Medicare Enrollment at Age 65.  It provides that: 

MassHealth members 65 and older who receive MassHealth Standard and who have an income at or less than 190% of the federal poverty level (FPL), must enroll in Medicare as a condition of MassHealth eligibility. Members who are not eligible for Medicare will not lose MassHealth.

It cites as its authority the regulation at 130 CMR 517.008 which requires applicants and members to obtain and maintain health insurance “available at no cost to them,” and provides that failure to do so may result in loss of eligibility.[1] 

It also describes the process for notice and outreach: 

• MassHealth sends a letter to its members who are Qualified Medicare Beneficiaries (QMB) from the Medicare Enrollment Support Project team at U Mass requiring the member to make an appointment to apply for Medicare benefits within 60 days of receiving the letter. Attached is a sample letter supplied to us by MassHealth.
• The Project team will make one or more outreach calls to each member and will assist in scheduling an appointment at SSA.
• If the member has not communicated with the outreach team after receiving the letter and one or more outreach calls, their MassHealth will be terminated.
• If there is a response, and the person has either scheduled an appointment on their own or the Project Team schedules it for them, then the Project Team will follow up in 6 months’ time. If the member has not applied for Medicare and been enrolled or denied as ineligible, the Project team will send a follow up letter and may require the member to enroll again. If there has been no response after 3 more months, the individual’s MassHealth will be terminated.
• A member who has been terminated can recover their MassHealth coverage without a new application if they call the Medicare Enrollment Support Project team and schedule an appointment with the SSA to apply for Medicare within 90 days of losing their MassHealth coverage.

This is additional information from MassHealth not included in the EOM:

• The Medicare Enrollment Support Project is operated out of U Mass and has a dedicated phone line with access to interpreter services: 877-935-1280. It will send follow-up notices and call during the 60 days that members have to respond to the initial notice. U Mass will offer to call SSA wait on hold and schedule the appointment, or the members can schedule on their own. Currently it is taking about 1-2 months to get an appointment at SSA. U Mass will call with a reminder before the appointment and for an update afterwards.
• The initial notices (sample copy attached) will include a fact sheet and insert addressed to SSA (sample attached), and will be mailed in Yellow envelopes that look like this:

• People who do not call U Mass within 60 days of the initial notice about scheduling an appointment will be terminated.
• U Mass will follow up at 6- and 9-month intervals for people who have scheduled appointments but are not yet enrolled in Medicare to determine if they were denied or need further assistance to apply. 

Advocacy Issues:

We think most of the people affected by this initiative do not have Medicare now because they do not have the work credits to qualify for Social Security Retirement benefits and premium free Medicare Part A.  We are told they can only apply in person at an SSA office and not by phone or online. This is a problem for citizens and non-citizens alike when going to SSA to apply for Medicare because without QMB they can’t enroll outside of open enrollment, may face late enrollment penalties, and will be charged a premium of $518 per month for Medicare Part A in addition to the Medicare Part B premium of $185 per month. QMB is the solution to this problem, but only if SSA and MassHealth are communicating with one another.  

In addition to the problems all MassHealth beneficiaries without premium free-Medicare Part A will have signing up for Medicare, non-citizens faced more problems. Some non-citizens who are eligible for MassHealth Standard will not be eligible for Medicare.  Without sufficient work credits, the only non-citizens eligible to purchase Medicare Part A are lawful permanent residents (green card holders) who have lived in the US for the last 5 years prior to the date they apply for Medicare. This is much narrower than the eligibility for MassHealth Standard which includes refugees, people granted asylum or withholding of removal, Cuban-Haitian Entrants, and victims of trafficking or domestic violence.

As far as we know, MassHealth is assuming any older adult on MassHealth Standard with income of 190% FPL is eligible for QMB without screening out those non-citizens who are not eligible for Medicare. 

Please be on the lookout for clients receiving these outreach notices and let the MLRI health unit (vpulos@mlri.org, ksymmonds@mlri.org, Jkaplan@mlri.org) know what your clients' are experiencing with U Mass and SSA. We don't want anyone losing coverage!