CMS has announced a Special Enrollment Period (SEP) for Medicare beneficiaries impacted by the COVID-19 pandemic. If your clients qualify, they will have another limited opportunity to make an election change for the current plan year.

Coronavirus Disruption

The pandemic and associated shelter-in-place orders have created a great deal of confusion and complication for current Medicare enrollees and newly eligible beneficiaries.

Many people have lost their jobs, and thus their job-based healthcare. At the same time, Social Security Administration offices have closed. People, especially people who are older and more vulnerable to COVID-19 complications, have been asked to stay home. Some people have been sick or have been caring for someone who is sick. All of this can make getting help with Medicare more difficult.

The COVID-19 National Emergency

On March 13, President Trump issued a proclamation declaring a national emergency concerning the COVID-19 outbreak. According to the proclamation, the national emergency officially began on March 1, 2020.

According to FEMA, all 50 states, the District of Columbia and four territories have been approved for major disaster declarations.

Disaster-Related SEPs

After a FEMA-declared weather-related emergency or major disaster, it is standard for CMS to issue a Medicare SEP for impacted beneficiaries. However, it was not clear whether an SEP would be allowed for beneficiaries impacted by the coronavirus pandemic.

On May 5, CMS issued a memorandum that clarified the issue. Medicare beneficiaries impacted by the pandemic will be granted an SEP.


The memorandum from CMS states that beneficiaries will be considered impacted by the emergency and therefore eligible for the SEP if they meet certain criteria:

  • They reside in an area where FEMA has designated an emergency or major disaster and for which FEMA has designed eligible to apply for individual or public level assistance, or they resided in such an area at the start of the incident period.
  • They had a valid election period during the incident period.
  • They did not make an election during the valid election period.

Again, all 50 states and the District of Columbia, as well as four territories, have been approved for major disaster declarations.

The SEP starts on March 1 and lasts for four calendar months.

Determining Eligibility

CMS has stated that beneficiaries will not be required to provide proof that they were affected by the pandemic in order to qualify for an SEP.

If any of your clients had an election period on or after March 1, 2020, and if they did not use this period to enroll or disenroll in a plan, they may qualify for an SEP based on the coronavirus national emergency.

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