MAPD Help Desk: Important Technical Information Regarding use of MARx Election Type Code “I-INITIAL COVERAGE ELECTION PERIOD (ICEP)” as of January 1, 2025

RELEASED BY CMS FEB 4, 2025:  This memorandum is a follow up to a prior MAPD plan update titled, “MAPD Help Desk: Important MARx Election Type Code and Special Election Period (SEP) Reason Code Updates Effective Calendar Year (CY) 2025” issued via the MAPD helpdesk on December 20, 2024, and the HPMS notification titled, “Release of Parts C and D Enrollment and Disenrollment Guidance” issued on August 8, 2024. This memorandum provides technical information regarding recent MARx updates to reflect the timeframe changes for use of the ICEP as described in the CY 2025 Medicare Advantage and Part D Final Rule which was effective January 1, 2025.

Effective January 1, 2025, the timeframe for use of Election Type Code “I-Initial Coverage Election Period (ICEP)” begins three months prior to the month an individual first has both Part A and Part B, and will end on the later of:

1. The last day of the second month after the month in which they are first entitled to Part A and enrolled in Part B; or
2. The last day of their Part B Initial Enrollment Period (IEP).

The new ICEP timeframe will first be applicable to those individuals who have both Part A and Part B based on age, disability or End Stage Renal Disease (ESRD) as of January 1, 2025. MARx will reject transactions using Election Type Code “I” under the new timeframe if the first date an individual has both Medicare Part A and Part B is prior to January 1, 2025.

The previous ICEP timeframe is still applicable to all individuals who first had both Part A and Part B prior to January 1, 2025. That is, the ICEP for these individuals began three months prior to the month the individual first had both Part A and Part B and will end or ended on the later of:

1. The last day of the month preceding entitlement to both Part A and Part B, or;
2. The last day of the individual’s Part B IEP.

EXAMPLES:

1. ICEP corresponding to an individual’s 65th birthday:

Mrs. Smith’s 65th birthday was on January 15, 2025. Mrs. Smith was eligible for Medicare Part A and Part B beginning January 1, 2025. She was entitled to Part A and enrolled in Part B effective January 1, 2025. Her ICEP overlaps with her IEP. In this scenario, her ICEP began on October 1, 2024 and ends on April 30, 2025 since April 30, 2025 is the last day of Mrs. Smith’s Part B IEP. A Medicare Advantage (MA) enrollment transaction is submitted in November 2024 using the “I” Election Type Code for an effective date of January 1, 2025. The enrollment transaction is accepted in MARx, because the first date Mrs. Smith has both Medicare Part A and Part B is January 1, 2025.

2. ICEP corresponding to a working individual who delays enrolling in Part B until January 1, 2025:

Mr. Adams’s 65th birthday was on April 20, 2020. He was eligible for Medicare Part A and Part B beginning April 1, 2020. Because he was still working and had health insurance provided by his employer, he decided not to enroll in Part B during his IEP, and only enrolled in Part A on March 20, 2020, with a Part A entitlement date of April 1, 2020. Upon retiring, he will have the opportunity to enroll in Part B (through a Part B special enrollment period (SEP)). He enrolls in Part B effective January 1, 2025. In this scenario, the date Mr. Adams had both Part A and Part B for the first time was January 1, 2025; therefore, his ICEP is October 1, 2024 through February 28, 2025. A MARx Medicare Advantage Prescription Drug (MA-PD) enrollment transaction using the “I” Election Type Code was submitted in December 2024 with an effective date of January 1, 2025. The enrollment transaction was accepted.

3. ICEP corresponding to a working individual who delays enrolling in Part B prior to January 1, 2025:

Mr. James’s 65th birthday was on November 16, 2020. He was eligible for Medicare Part A and Part B beginning November 1, 2020. Because he was still working and had health insurance provided by his employer, he decided not to enroll in Part B during his IEP, and only enrolled in Part A on September 30, 2020 with a Part A entitlement date of November 1, 2020. Upon retiring in November 2024, he will have the opportunity to enroll in Part B (through a Part B SEP). He enrolled in Part B on November 12, 2024, and requested his Part B to be effective as of December 1, 2024. In this scenario, the date Mr. James had both Part A and Part B for the first time was December 1, 2024, which is before the January 1, 2025 effective date of the new ICEP timeframe described in the CY 2025 Medicare Advantage and Part D Final Rule. A MARx enrollment transaction was submitted in December 2024 using the “I” Election Type Code for a January 1, 2025 effective date. The enrollment transaction was rejected. Mr. James’s ICEP was September 1, 2024 through November 30, 2024. His ICEP timeframe was based on the end date of the prior (old) rule, which is the last day of the month preceding the month he was first entitled to both Part A and Part B.

For more information regarding CY 2025 Medicare Advantage and Part D enrollment and disenrollment guidance, please refer to the Medicare Advantage and Part D Enrollment and Disenrollment Guidance available at: https://www.cms.gov/medicare/enrollment-renewal/managed-care-eligibility-enrollment.

Plans are encouraged to contact the MAPD Help Desk for technical questions or concerns at: 1-800-927-8069 or e-mail mapdhelp@cms.hhs.gov. Part C and Part D enrollment and disenrollment policy related questions should be directed to:  https://enrollment.lmi.org/DEEPmailbox/mailbox/.