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Key points
- VA health care is not current-employment group coverage for the usual Part B Special Enrollment Period, while VA prescription coverage may be creditable for Part D; these are different tests.[1][2]
- CMS-L564 documents group health plan coverage based on current employment and is generally submitted with CMS-40B when requesting Part B under a qualifying Special Enrollment Period.[3]
- Part B late-enrollment penalties are generally 10% for each full 12-month period you could have had Part B and usually last as long as you have Part B.[4]
- TRICARE For Life generally requires both Medicare Part A and Part B; Part C and Part D are not required for TFL.[5][6]
There is no single Medicare form for every veteran. The form you need depends on whether you are working, already have Part A, are appealing an income-related surcharge, or are filing a TRICARE claim. Use official instructions and confirm your own dates before delaying Part B or changing coverage.[3][4]
First, separate Part B rules from Part D rules
VA health care generally is not coverage based on current employment, so it usually does not create the job-based Special Enrollment Period that lets someone delay Part B without a possible penalty. That does not mean every person with VA coverage automatically owes a penalty: active-duty TRICARE beneficiaries and other Special Enrollment Period situations have different rules. Check your eligibility and enrollment window with Social Security or Medicare before delaying Part B.[1][3]
What is CMS-L564 used for?
CMS-L564 is used to document group health plan coverage based on current employment. You complete Section A, an employer completes Section B, and you generally submit it with CMS-40B to Social Security when requesting Part B under a qualifying Special Enrollment Period. COBRA and retiree coverage do not generally create this current-employment SEP, so confirm your employment and coverage dates with Social Security.[3]
This form is not a general certificate that any past insurance lets you postpone Part B. The timing matters: the job-based SEP generally ends eight months after employment or the group coverage ends, whichever comes first. Keep records of the employer, coverage dates, and the date you stopped working.[3]
When might CMS-40B be the right Part B form?
CMS-40B is generally used to request Part B when you already have Part A or are using a qualifying Special Enrollment Period. It is not a universal three-month-before-65 instruction. Some people are automatically enrolled, while others use the Social Security or Medicare application for their situation. If employment coverage must be documented, pair CMS-40B with CMS-L564 as instructed.[7][3]
How do enrollment windows affect penalties?
Your Initial Enrollment Period lasts seven months: the three months before you turn 65, your birthday month, and the three months after. If you delay Part B without a qualifying Special Enrollment Period, the late-enrollment penalty is generally 10% for each full 12-month period you could have had Part B, usually for as long as you have Part B.[3][4]
The General Enrollment Period runs January 1 through March 31. Coverage generally starts the month after you sign up, and a late-enrollment penalty may apply if no Special Enrollment Period applies. Medicare dates and start rules can change, so use the current Medicare guidance and your own eligibility record rather than an old year-specific deadline.[3][4]
What is SSA-44 used for?
SSA-44 is the work-step form for asking Social Security to reconsider an Income-Related Monthly Adjustment Amount, or IRMAA, after a qualifying life-changing event such as work stoppage or reduction, marriage, divorce, a spouse's death, or loss of income-producing property. Social Security generally uses an earlier tax return to set IRMAA, so a major income change may justify a request for reconsideration.[8][9]
What does DD Form 2642 do for TRICARE claims?
Most providers file TRICARE claims, but you may need to file a claim yourself in situations such as care while traveling, care from a nonparticipating provider, or some TRICARE For Life claims. Use the current TRICARE claim instructions and DD Form 2642 only when the applicable claims processor requires it; the form is not a universal requirement for every visit.[5]
Most TRICARE-eligible retirees and dependents who are entitled to Medicare need both Part A and Part B to have TRICARE For Life. Active-duty beneficiaries and some other situations have different rules. If both Medicare and TRICARE cover a service, Medicare generally pays first and TRICARE pays last. Confirm eligibility and effective dates with TRICARE and Social Security before making a change.[5][6]
A practical forms checklist
- Identify your coverage Write down whether you have VA health care, active employment coverage, COBRA, retiree coverage, TRICARE For Life, or another Medicare-related program. The rules are not interchangeable.[1][3][5]
- Check your enrollment window Find your seven-month Initial Enrollment Period and ask whether a qualifying Special Enrollment Period applies before you postpone Part B.[3][4]
- Match the form to the task Use CMS-L564 with CMS-40B when current-employment coverage must be documented; use SSA-44 for an IRMAA reconsideration request; use DD Form 2642 only when TRICARE's current claim instructions call for it.[3][8][5]
- Use current official instructions Download the current forms from the government agency involved. The VAF forms library can help you locate topics, but official instructions control.[3]
If you want help organizing questions before speaking with Social Security, Medicare, or TRICARE, you can book a call with Veterans Advantage Financial®. We are an independent insurance agency, not part of or endorsed by Medicare, CMS, VA, TRICARE, Social Security, or any government agency. You can also read the Veterans Medicare FAQ and VA health care and Medicare guide.
Common questions
Can VA health care let me delay Part B?
VA health care generally is not current-employment group coverage for the usual Part B Special Enrollment Period. Active-duty TRICARE and other situations can differ, so confirm your circumstances before delaying Part B.[1][3][4]
Do I need CMS-L564 if I have COBRA or retiree coverage?
CMS-L564 documents group coverage based on current employment. COBRA and retiree coverage do not generally create the job-based Part B Special Enrollment Period; ask Social Security to review your dates.[3]
Sources
- U.S. Department of Veterans Affairs. “VA health care and other insurance.” VA.gov, last updated July 14, 2025. va.gov/resources/va-health-care-and-other-insurance
- Medicare.gov. “Creditable prescription drug coverage.” medicare.gov/health-drug-plans/part-d/basics/creditable-coverage
- Medicare.gov. “When does Medicare coverage start?” medicare.gov/basics/get-started-with-medicare/sign-up/when-does-medicare-coverage-start
- Medicare.gov. “Avoid late enrollment penalties.” medicare.gov/basics/costs/medicare-costs/avoid-penalties
- TRICARE (Defense Health Agency). “Q&A: How does TRICARE For Life work with Medicare?” TRICARE Newsroom, December 14, 2023. newsroom.tricare.mil/News/TRICARE-News/Article/3617884/qa-how-does-tricare-for-life-work-w
- TRICARE (Defense Health Agency). “TRICARE For Life.” TRICARE.mil, last updated September 25, 2026. tricare.mil/tfl
- Medicare.gov. How do I sign up for Medicare? medicare.gov/basics/get-started-with-medicare/sign-up/how-do-i-sign-up-for-medicare
- SSA.gov. Lower your IRMAA ssa.gov/medicare/lower-irmaa
- SSA.gov. Premiums: rules for higher-income beneficiaries ssa.gov/benefits/medicare/medicare-premiums.html
Sources checked October 11, 2026. Dollar amounts are for 2026 unless noted.
This is general education, not personal advice, and it isn’t a recommendation of any specific plan. Veterans Advantage Financial® is a licensed insurance agency, not affiliated with or endorsed by Medicare, Social Security, VA, TRICARE or any government agency. Plan availability, costs and benefits vary by plan, county and year. Check your own situation with the agency or plan before making changes.
Christopher Duncan
Christopher founded Veterans Advantage Financial® and has helped people with Medicare since 2006. He is a licensed insurance agent in all 50 states and DC (NPN 8613503). His dad, Wallace, is a Vietnam-era veteran.