ESRD With COBRA and Medicare: Which Insurance Pays First?

With ESRD and COBRA, Medicare is generally the primary payer. COBRA is continuation coverage — not active employer group health coverage — so the 30-month ESRD coordination period does not apply. Medicare pays first and COBRA pays second for covered services.

Frequently Asked Questions

Does the 30-month coordination period apply if I have COBRA?
No. The 30-month ESRD coordination period only applies when you have active employer group health coverage. COBRA is continuation coverage — not active employer group health coverage — so Medicare is generally primary from the start.
Can I keep COBRA after enrolling in Medicare for ESRD?
Yes. COBRA must be allowed to continue after you enroll in Medicare. However, COBRA typically pays secondary to Medicare — Medicare pays first and COBRA covers some remaining costs.
What if I had active employer coverage when ESRD started, then elected COBRA after?
If active employer coverage was in place when ESRD eligibility began, the 30-month coordination period applies to that employer coverage. When that coverage ends and you elect COBRA, Medicare generally becomes primary with COBRA secondary. Timing matters — confirm the transition rules with your plan.