Medicare & Employer Health Coverage - a Coordination Conversation

Copyright 2020 – Not to be reproduced without express permission of benefitexpress
Webinar for Plan
Sponsors: Medicare &
Employer Health
Coverage -
a Coordination
Conversation

Webinar Presenters
PRESENTER
Lawrence (Larry) Grudzien, JD, LLM is an attorney
practicing exclusively in the field of employee benefits.
MODERATOR
Julia Goebel is Chief Marketing Officer, benefitexpress
2

3
Case Study: Restaurant/Retailer
~65,000
employees
~18,000
eligible
Restaurants
Benefits Enrollment
Technology &
Administration
Decision
Support
ACA & Related
Compliance
Reimbursement Solutions
(HSA, FSA, HRA)
COBRA &
Direct Bill
Initially Contracted
Consideration
Solutions Added
Industry Size
Client Needs
Situation Overview
▪ Client required significant Benefits Administration
technology enhancements compared to its current
solution set via legacy provider of 13 years
– Partnered with herronpalmer to assess Benefits
Admin strategy and review marketplace
▪ Benefitexpress leveraged strong industry reputation
with competitive pricing to win business in late 2018
▪ Upgrades to enrollment website (including customizations)
▪ On-shore call center for employee service
▪ Billing arrear administration for variable-hour employees
▪ Improved reporting and transparency

4
Case Study: Healthcare System
~26,000
employeesHealthcare
▪ Consolidation of administration across multiple health entities
▪ State-of-the-art technology
▪ Support for PeopleSoft and UltiPro
▪ Introduction of closed-loop payroll and capture of retro
payroll deductions
▪ Following hospital system merger, broker (Conner
Strong) was assigned to find a BenAdmin solution that
could support the consolidated entities and help
harmonize plan design, vendors, policies, and cost
▪ Benefitexpress invited to compete for business based on
its strong relationship with Conner Strong
▪ Benefitexpress was selected over incumbents (bswift and
Fidelity) in 2018
Reimbursement Solutions
(HSA, FSA, HRA)
Initially Contracted
Consideration
Solutions Added
Industry Size
Client Needs
Situation Overview
Benefits Enrollment
Technology &
Administration
Decision
Support
ACA & Related
ComplianceCOBRA &
Direct Bill

5
Agenda
• Medicare Secondary
Payer Rules
• Medicare Part D
• COBRA
• Other areas

6
6
PAYER RULES
MEDICARE SECONDARY

7
Medicare Secondary Payer Rules
Can an employer in any way encourage active employees to elect out of employer
sponsored health coverage when they are eligible for Medicare?
• No. The Medicare Secondary Payer statute prohibits a group health plan from “taking
into account” the Medicare entitlement of an active employees or family members if
such employees are still considered in “current employment status.”
• Employers are prohibited from discouraging employees from enrolling in their group
health plan or from offering “financial or other incentive for an individual entitled to
Medicare” not to enroll (or to terminate enrollment) under” a group health plan that
would otherwise be a primary plan.
• The above prohibition does not apply to employers with less than 20 employees
for each working day in at least 20 weeks in either the current or the preceding
calendar year.
• This test must be run at the time the individual receives the services for which
Medicare benefits are claimed.

8
What does “current employment status” mean?
• A person has current employment status
if he or she is actively working as an employee,
is the employer (including a self-employed person),
or is associated with the employer in
a business relationship.

9
Can an employer drop employees or dependents who become disabled from
employer sponsored health coverage when they become eligible for Medicare if
such employees are considered in “current employment status”?
• No. The Medicare Secondary Payer statute prohibits a group health plan from “taking
into account” the Medicare entitlement of disabled employees or a family member .
• An otherwise covered individual who isn’t actively working is nevertheless considered
to be in “current employment status” if he or she:
- is receiving disability benefits from an employer for up to six months; or
- retains employment rights in the industry, hasn’t had his or her employment
terminated by the employer, isn’t receiving disability benefits from an employer
for more than six months or from Social Security, and has group health coverage
other than COBRA coverage (whether or the individual receives pay).

10
• This prohibition does not apply
to employers with less than 100
employees on a typical business day
during the previous calendar year.
• This means that the employer must
have 100 or more employees, whether
full-time or part-time, on at least 50%
of its regular business days during the
previous calendar year.

11
Who is considered a "disabled
individual" under the MSP rules?
• Disabled individuals generally are those
individuals who are under age 65 and
who have been entitled to Social Security
disability benefits for 24 months.
11

12
Which employees are counted in determining the number of
employees for the “small employer exception”?
• In counting an employer’s employees for purposes of the small employer exceptions,
the following rules apply:
⁃ Leased employees must be counted if they would be counted as employees
under code § 414(n);
⁃ All of the employees of the members of an “affiliated service group” (as defined in
code § 414(m)) must be counted as if they were employees of a single employer; and
⁃ All of the employers that are considered to be a “single employer” under
code § 52(a) or 52(b) must be treated as a single employer.

13
What does it mean to “take into account” Medicare entitlement?
• Under the MSP statute, a group health plan may not take into account:
⁃ the age-based Medicare entitlement of an individual (or the individual’s spouse) who
is covered under the plan by virtue of the individual’s current employment status ;or
⁃ the disability-based Medicare entitlement of an individual (or the individual’s family
member) who is covered under the plan by virtue of the individual’s current
employment status.
• A plan must provide a current employee or a current employee’s spouse who is age 65
or older with the same benefits, under the same conditions, as are provided to
employees and spouses who are under age 65.

14
Examples of employer or insurer actions that constitute an impermissible “taking into
account” are provided in the regulations and include the following:
• Failure to pay primary benefits;
• Offering coverage that is secondary to Medicare to individuals entitled to Medicare;
• Terminating coverage because the individual has become entitled to Medicare, except
as permitted under COBRA;
• Denying or terminating coverage because an individual is entitled to Medicare on the
basis of disability without denying or terminating coverage for similarly situated
individuals who are not entitled to Medicare on the basis of disability;
• Imposing limitations on benefits for a Medicare-entitled individual that
don’t apply to others enrolled in the plan;

15
• Charging a Medicare-entitled individual higher premiums;
• Requiring a Medicare-entitled individual to wait longer for coverage to begin;
• Paying providers and suppliers less for services furnished to a Medicare beneficiary than
for the same services furnished to an enrollee who is not entitled to Medicare;
• Providing misleading or incomplete information that would have the effect of inducing a
Medicare-entitled individual to reject the employer plan, thereby making Medicare the
primary payer;
• Including in its health insurance cards, claims forms, or brochures distributed to
beneficiaries, providers, and suppliers' instructions to bill Medicare first for services
furnished to Medicare beneficiaries without stipulating that such an action may be taken
only when Medicare is the primary payer; and
• Refusing to enroll an individual for whom Medicare would be the secondary payer, when
enrollment is available to similarly situated individuals for whom Medicare would not be
the secondary payer.

16
What are considered “incentives”
under the rules?
• Employers are prohibited from discouraging
employees from enrolling in their group health
plans or from offering any “financial or other
incentive” for an individual entitled to
Medicare “not to enroll (or to terminate
enrollment) under” a group health plan that
would otherwise be a primary plan.
• The prohibition applies “even if the payments
or benefits are offered to all other individuals
who are eligible for coverage under the plan.”

17
Can a Medicare or Medigap premiums be reimbursed
by an employer for an active employees?
• Generally no, but there are three exceptions:
⁃ A small employer follows the rules under Notice 2015-17,
⁃ A small employer can adopt a Qualified Small Employer HRA, or
⁃ A large or small employer can adopt an Individual coverage HRA in 2020 or after.
• If an employer offers to reimburse Medicare premiums for its active employees,
it creates an employer payment plan because Medicare is not considered
employer group coverage.

18
Exception under IRS Notice 2015-17:
An HRA can pay for or reimburses Medicare Part B or Part D premiums if its is integrated
with another group health plan offered by the employer for purposes of the annual dollar
limit prohibition and the preventive services requirements and meets the following rules:
• The employer offers a group health plan (other than the employer payment plan)
to the employee that does not consist solely of excepted benefits and offers
coverage providing minimum value;
• The employee participating in the employer payment plan is
actually enrolled in Medicare parts A and B;
• The HRA is available only to employees who are enrolled in
Medicare part A and part B or part D; and
• The employer payment plan is limited to reimbursement of Medicare part B or part D
premiums and excepted benefits, including Medigap premiums.

19
Exception under IRS Notice 2015-17:
• Note that to the extent such an arrangement is available to active employees,
it may be subject to restrictions under other laws such as the Medicare secondary
payer provisions.
• An employer payment plan that has fewer than two participants who are current
employees (for example, a retiree-only plan) on the first day of the plan year is
not subject to the market reforms and, therefore, integration is not necessary
to satisfy the market reforms.

20
Exception under a QSEHRA:
• Only available for employers who are not ALEs who do not sponsor a group health plan
• Plan must meet eligibility and same terms requirements
• Employers with 20 or more employees are subject to the
Medicare Secondary Payer Rules.

21
Exception under the ICHRA:
• Can be used by both large and small employers.
• Eligible employees must not be eligible for group
medical coverage.
• Cannot target just employees eligible for Medicare.
• Must meet group and benefit requirement.
• To avoid violation of the Medicare Secondary
Payer rules, the employee must be able to be
reimbursed for other medical expenses other
than Medicare premiums.

22
Do any special rules apply if an employer participates in multiemployer
or multiple employer plan?
• Yes, With respect to age-based Medicare entitlement, the MSP statute provides that if
at least one of the employers in the plan has 20 or more employees, then the group
health plan will be subject to the MSP rules.
• However, the plan may elect not to have the age-based MSP rules apply to employees
of employers in the plan that have fewer than 20 employees.
• A different rule applies to multiemployer and multiple employer plans under the
disability-based Medicare entitlement provisions.
• Under these provisions, if any one employer in the plan employed 100 or more
employees on at least 50% of its regular business days during the previous calendar
year, the plan will be considered to be a large group health plan subject to the MSP
rules for disabled employees.

23
Are there any special rules for Medicare eligibility
or entitlement based on ESRD?
• Yes, a group health plan (including a retiree medical plan) cannot take into account an
individual’s ESRD-based Medicare eligibility or entitlement for the first 30 months of
such eligibility or entitlement.
• Medicare generally must be the secondary payer for the first 30 months of an ESRD
patient’s Medicare eligibility or entitlement (and will be primary thereafter.)
• A plan may not otherwise differentiate in benefits provided under the plan between
ESRD patients and other individuals covered under the plan based on the existence of
ESRD, the need for renal dialysis, or in any other manner.

24
• These prohibitions apply regardless of whether the individual has
coverage by virtue of current employment status, and there is no
exception for small employers.
• Medicare will remain primary, however, for an individual who was
entitled to Medicare due to age or disability on a primary basis at the
time he or she becomes eligible for ESRD-based Medicare.

25
Does an employer’s prescription drug plan have to be coordinated with
employee’s Medicare Part D drug plan?
• Yes. The MSP rules are triggered when individuals
who are enrolled in group health plans offering
prescription drug coverage also enroll
in Part D plans.
• Part D plans and group health plans are
generally required to comply with MSP laws
and any other federal and state laws
establishing payers of last resort.

26
Can an employee elect out of employer
coverage on their own and elect Medicare?
• There is nothing preventing an employee
electing out of employer coverage
on his or her own.

27
Are Health FSAs, HRAs Archer MSAs or HSAs subject to these rules?
• Health FSAs, HSAs, and Archer MSAs are not subject to the MSP Rules;
• HRAs are subject to the MSP Rules.
• ICHRAs have special exception.
• CMS has indicated that for MSP purposes, health FSAs (as well as HSAs
and Archer MSAs) aren’t group health plans and aren’t subject to being
a primary payer under MSP laws.
• HRAs, however, are group health plans subject to the MSP rules—information
about HRAs should be reported to CMS in the same manner as group health
plan information is reported.

28
If an employee continues to be covered under an employer provided health
coverage, will he or she be penalized when he or she decides to elect Medicare?
• No It is extremely important that an employee enrolls in Medicare during his or her initial
enrollment period.
• If an employee does not, he or she will be subject to late charges or a premium surcharge
• The Part B premium goes up 10 percent for each 12-month period the employee was
eligible but does not enroll. The increase in the Part A premium (if the employee has to pay
a premium) is 10 percent no matter how late the employee enrolls.
• The employee may enroll in Part B or premium Part A at any time he or she is covered
under another group health plan.
• However, the employee may also choose to wait and enroll during a special
eight-month period. This special period would start with the month the employee or
his or her spouse stops working or when he or she is no longer covered by the
employer plan, whichever comes first.

29
Once a retiree becomes eligible for Medicare, can retiree coverage
be coordinated with Medicare?
• Yes, EEOC provided final regulations that allows employers that provide retiree
health benefits to continue the longstanding practice of coordinating those benefits
with Medicare (or comparable state health benefits) without violating the
Age Discrimination in Employment Act (ADEA).
29
29

30
Are there any penalties if an employer violates these
Medicare Secondary Payer rules?
• The federal government and Medicare recipients are authorized to recover double
damages from group health care plans that treat Medicare as the primary payer in
violation of the rules.
• Violation of the financial incentives prohibition is subject to a civil money penalty of up
to $5,000 for each violation.
• Code Section 5000 also imposes an excise tax of 25% of expenses on all employers,
other than certain governmental entities, or employee organizations whose group
health care plans fail to comply with the Medicare secondary payer rules. Employers or
employee organizations may appeal HCFA determinations of a failure to comply with
Code Section 5000.
• The government has three years to collect health care payments that were wrongly paid
by Medicare from the primary party.

31
Is there any reporting requirements under the Medicare
Secondary Payer Rules?
• Yes Under Section 111 of the Medicare, Medicaid, and SCHIP Extension Act of
2007 (MMSEA), new mandatory reporting requirements was added for group
health plans and for non-group health plan arrangements (liability insurance
including self-insurance, no-fault insurance and workers' compensation).

32
 Who is required to report the mandatory reporting
information to CMS?
• The responsibility for reporting information to help identify whether a group health
plan is (or has been) a primary plan to Medicare falls upon the “entity serving as an
insurer or third party administrator for a group health plan...and, in the case of a group
health plan that is self-insured and self-administered, a plan administrator or fiduciary.”
• CMS refers to entities that are responsible for complying with the reporting
requirements under Section 111 as “responsible reporting entities” (RREs).

33
What plans are subject to the Section 111 reporting requirements?
• Many types of group health plans are subject to the MSP rules in general.
• Health FSAs and HSAs are not, but HRAs are.
⁃ No reporting if annual benefits are less than $5,000.
⁃ ICHRAs can be subject.

34
What information should be reported to CMS?
• CMS must be provided information regarding all individuals meeting the definition of
an “active covered individual.”
• In general, an active covered individual is someone who may be Medicare eligible and
currently is employed, or the spouse or other family member of a worker who is
covered by the employed individual's group health plan and who may be eligible for
Medicare and for whom Medicare would be secondary payer.

35
For mandatory reporting purposes, CMS has defined “active covered individuals” in
its User Guide to include all individuals covered in the group health plan who—
• are ages 45 through age 64 with coverage based on their own or
a family member’s current employment status;
• are age 65 and older with coverage based on their own or a spouse’s
current employment status;
• have been receiving kidney dialysis or have received a kidney transplant,
regardless of their own or a family member's current employment status; or
• are under age 45, are known to be entitled to Medicare, and have coverage
in the plan based on their own or a family member’s current employment status
regardless of their age.

36
How and when should information be reported to CMS?
• Information may be submitted only through an electronic process under which new
group health plan RREs will register online through a secure website using an interactive
web portal designed for that purpose.
• Once data has been submitted, CMS will work with the RREs to set up the data
reporting and response process, and it will use the information to ensure that payment
is made in the proper order and to pursue recovery activities.
• CMS has indicated that RREs must submit information on a quarterly basis

37
What the penalties for failure to comply with Section 111
reporting requirements?
• Entities that fail to comply with the MMSEA Section 111 reporting requirements are
subject to a civil monetary penalty of $1,000 for each day of noncompliance for each
individual for which information should have been submitted.
• This fine is in addition to any other penalties prescribed by law and any potential claims
under the MSP regulations (e.g., a claim by Medicare that the group health plan should
have paid primary to Medicare).

38
PART D
MEDICARE

39
Medicare Part D
For those employee who are eligible for Medicare Part D benefits,
what disclosure must an employer provide them?
• Each year before October 15th, an employer
must provide a notice to those eligible employees
whether its prescription drug plan is either
“creditable” or “noncreditable.”

40
Medicare Part D
In what other situations must the notice be distributed?
• Prior to an individual's initial enrollment period (IEP) for part D—the timing of the IEP
varies according to several factors;
• Prior to the effective date of coverage for any part D eligible individual that enrolls in the
employer's prescription drug coverage—the timing of the effective date of coverage
varies for each individual;
• Whenever the employer no longer offers prescription drug coverage or changes it so
that it is no longer creditable or becomes creditable—the timing of a change in coverage
generally varies according to the employer's actions; and
• Upon request by the part D eligible individual—the timing of a request varies according
to the individual's actions.

41
Medicare Part D
Why does an employer have to give this notice?
• If an employer’s prescription drug coverage is not considered “creditable,” the employee
may be subject to a late enrollment penalty.
• A late enrollment penalty may apply after experiencing a lapse in creditable prescription
drug coverage for any continuous period of 63 days or longer at any time after the end
of the individual’s IEP for Part D.
• The penalty amount will be the base beneficiary premiums that would otherwise apply
will be increased by the greater of (1) an amount that CMS determines is actuarially
sound for each uncovered month in the same continuous period of eligibility; or (2) 1%
of the base beneficiary premium for each uncovered month in the period.

42
Medicare Part D
Are there any penalties if an employer either does not provide the
notice or provides an incorrect notice to employees?
• Neither the law nor the regulations provide mechanisms for CMS to enforce
penalties or other sanctions against employers that fail to comply with the
disclosure requirements, other than those claiming the retiree drug subsidy.
• However, employers that don’t comply with such requirements are likely
to encounter adverse employee relations issues.

43
Medicare Part D
Are there any other disclosures that an employer must make under
Medicare Part D?
• Group health plan sponsors must also notify CMS about creditable coverage status.
• The Disclosure to CMS Form that must be used to disclose to CMS whether the group
health plan coverage is creditable must be completed and sent electronically through the
CMS website (hard copies are not generally allowed).
• There is one exception, however.
• Entities without Internet access can request that copies of the Disclosure to CMS Form be
faxed to them, presumably for completion and return to CMS on hard copy
• Notice must be given annually within 60 days after the end of the plan year.

44
MEDICARE
COBRA &

45
COBRA
When can the entitlement of Medicare
terminate COBRA coverage?
• When any qualified beneficiary (including the
covered employee) first becomes entitled to
Medicare after electing COBRA coverage, his
or her COBRA coverage can be terminated
early (i.e., before the end of the maximum
coverage period).
• This rule does not, however, affect the COBRA
rights of other qualified beneficiaries in a family
unit who are not entitled to Medicare (for
example, the spouse and dependent children
of a Medicare-entitled former employee).

46
COBRA
When does Entitlement to Medicare extend the
period of COBRA coverage?
• When a covered employee’s qualifying event (i.e., a termination of employment or
reduction of hours) occurs within the 18-month period after the employee becomes
entitled to Medicare, the employee’s spouse and dependent children (but not the
employee) become entitled to COBRA coverage for a maximum period that ends 36
months after the covered employee becomes entitled to Medicare.
• The covered employee remains entitled to a basic maximum period that ends 18 months
after the termination of employment or reduction of hours.

47
COBRA
Does the entitlement to Medicare before electing COBRA
terminate COBRA coverage?
• No. When any qualified beneficiary (including the covered employee)
is entitled to Medicare before electing COBRA, he or she still has the right
to elect COBRA coverage.
• The COBRA offer cannot be withheld because of Medicare entitlement.
• And this coverage may not be terminated early because of the
Medicare entitlement.

48
COBRA
Is entitlement to Medicare ever a first qualifying event
to trigger COBRA?
• The covered employee’s entitlement to Medicare is one of COBRA’s
listed qualifying events.
• It is a qualifying event only for the spouse and dependent children,
not for the covered employee,
• But because Medicare entitlement will only infrequently cause a loss of coverage
under a group health plan, it will rarely be a COBRA qualifying event.
• It is permissible under the MSP rules for Medicare entitlement to cause a loss of
coverage for covered retired employees (and their spouses and dependent children).

49
COBRA
Will enrolling in Medicare preserve an employee’s special enrollment
rights under Medicare?
• COBRA coverage is not considered a group health plan
based upon current employment.
• Individuals who, in order to retain their COBRA coverage,
do not enroll in Medicare when first eligible will not have
special enrollment rights under Medicare and may expect
to pay more for Medicare when COBRA coverage ends.

50
COBRA
Must a plan still offer COBRA coverage to retirees when alternative
retiree coverage is offered?
• Yes. Alternative retiree coverage might be offered under the plan covering active
employees, or it might be offered under a separate retiree plan.
• In either case, the employer cannot avoid its obligation to offer COBRA coverage in
connection with the employee’s retirement simply by providing alternative retiree
coverage.

51
COBRA
Must a plan offer COBRA to
retirees when alternative
retiree coverage expires?
• The regulations make it clear that if
a retiree (and his or her family) are
offered but do not elect COBRA
and instead choose alternative
retiree coverage available for a
fixed period of time, no COBRA
election must be offered when the
retiree coverage expires.
• This result would be the same
whether retiree coverage is offered
under a combined retiree/active
plan or under a retiree-only plan.

52 52
AREAS
OTHER

53
HSAs
When is an individual no longer eligible to
contribute to an HSA?
• Code § 223(b)(7) reads as follows: “Medicare eligible individuals. The [contribution limit]
under this subsection for any month with respect to an individual shall be zero for the
first month such individual is entitled to benefits under title XVIII of the Social Security
Act and for each month thereafter.
• An individual can become entitled to Medicare benefits (under Title XVIII of the Social
Security Act) for three reasons: age, disability, or end-stage renal disease (ESRD).
• Entitlement to Medicare Part A is automatic for some individuals (i.e., a separate
application is not required) because they have already applied for and are receiving
Social Security or Railroad Retirement Act benefits.
• Other individuals must file an application in order to become entitled to Part A benefits.

54
HSAs
Are there any special rules if an employee enrolls in
Medicare after age 65?
• In Information Letter 2016-0082, the IRS indicated that health savings account (HSA)
holders cannot make contributions for months of retroactive Medicare coverage.
• This because Medicare coverage typically begins with the month an individual
turns age 65, but the actual commencement date depends on when the individual
applies for Medicare (or Social Security or Railroad Retirement benefits that trigger
Medicare coverage).
• Individuals who delay applying for free Medicare Part A are covered retroactively to the
month they attained age 65 or for six months, whichever is less.
• The IRS explained that the Code sets a zero-contribution limit for months of Medicare
coverage and that rule has no exceptions, so months of retroactive Medicare must also
reduce HSA contributions.

55
HSAs (cont.)
Are there any special rules if an employee enrolls in
Medicare after age 65?
• As a result, an HSA account holder who overcontributes because of retroactive Medicare
coverage can be subject to a subject to a 6% excise tax under Code Section 4973, unless
the excess contribution and earnings are withdrawn by the federal tax return filing
deadline (including extensions) for the contribution year. That is April 15, 2020 for 2019.
• Timely withdrawals of excess contributions are not subject to the 20% additional tax for
non-medical distributions.
• The additional income tax also does not apply to distributions made after an HSA
account holder attains age 65, so even if the excess is not timely withdrawn, it can be
withdrawn later without incurring this additional tax.

56
HSAs
Can an HSA be used to reimburse an individual
for Medicare premiums?
• Yes. Deductible health insurance premiums (other than for a Medicare supplemental
policy) for an account holder who is age 65 or older can be paid or reimbursed through
an HSA on a tax-free basis, including medical premiums for an employer’s insured or
self-insured retiree health coverage.
• When premiums for Medicare Part A (hospital and inpatient services), Part B (physician
and outpatient services), Part C (Medicare HMO and PPO plans), or Part D (prescription
drugs) are deducted from Social Security benefit payments received by an account
holder who is age 65 or older, he or she can take a tax-free HSA distribution equal to
the Medicare premium deduction.
• HSAs generally cannot be used by retired account holders for their health insurance
premiums prior to age 65—with the exception of COBRA coverage (or premiums paid
while receiving unemployment.

57
HIPAA
Is Medicare coverage considered
“creditable coverage” for
HIPAA purposes?
• Medicare is subject to HIPAA’s certification
requirements under the PHSA and thus
count as creditable coverage, but they are
not otherwise subject to HIPAA’s portability
provisions (e.g., PCEs, special enrollments,
and nondiscrimination) because they do
not constitute “group health plan” coverage
as defined in the PHSA, ERISA, or the Code.

58
QUESTIONS?

Julia Goebel
Chief Marketing Officer
jgoebel@mybenefitexpress.com
Attorney at Law
larry@larrygrudzien.com
Larry Grudzien
Contact information

Medicare & Employer Health Coverage - a Coordination Conversation

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