ESRD Coordination
End-stage renal disease (ESRD) Medicare eligibility triggers a 30-month coordination period. During the first 30 months of ESRD Medicare eligibility, the employer plan is primary (for employers with 20+ employees). After 30 months, Medicare becomes primary. Tracking the 30-month coordination period is critical — errors can result in MSP violations.
Disability Medicare Coordination
For employees who are Medicare-eligible due to disability, the employer plan is primary if the employer has 100 or more employees. If the employer has fewer than 100 employees, Medicare is primary. The 100-employee threshold is based on the number of employees on each working day in 20 or more calendar weeks in the current or preceding year.
Tracking Requirements
Pro Tip
Tracking ESRD and disability Medicare coordination requires a systematic process. For ESRD, track the date of Medicare eligibility and calculate the 30-month coordination period end date. For disability, track the employer's employee headcount to determine the applicable MSP rule. Work with your TPA to implement automated tracking and alerts for coordination period changes.