Quick answer
If you are turning 65 now and you are entitled to Medicare Part A, you generally need to have Medicare Part A and Part B to keep CHAMPVA. Under 38 CFR § 17.271, people who reach age 65 on or after June 5, 2001, and are entitled to Part A must be enrolled in Part B for CHAMPVA to continue as secondary coverage.
Current VA guidance says a Medicare Advantage plan (Part C) also meets the CHAMPVA Medicare requirement because it provides Medicare Part A and Part B benefits. Medicare Part D is not required to keep CHAMPVA.
If you are age 65 or older but not entitled to Medicare Part A, the regulation allows you to retain CHAMPVA. VA requires proof of that Medicare status, generally a Social Security Administration Notice of Disallowance.
There is a narrow grandfather rule for people who were already age 65 or older before June 5, 2001. That exception is explained below, but it will not apply to someone who is turning 65 today.
Start the Medicare process before your 65th birthday
VA's current CHAMPVA Guidebook instructs CHAMPVA beneficiaries to enroll in Medicare 90 days before their 65th birthday. That lines up with the start of Medicare's normal Initial Enrollment Period.
Medicare's current sign-up guidance says the Initial Enrollment Period generally lasts seven months:
- the 3 months before the month you turn 65;
- the month you turn 65; and
- the 3 months after the month you turn 65.
For a CHAMPVA beneficiary who must have Part B to stay eligible, the safest practical approach is to deal with Medicare as soon as that three-month pre-birthday window opens rather than waiting until the birthday month.
Medicare's coverage-start rules say that when you enroll in Part B before the month you turn 65, Part B generally starts the month you turn 65. If you enroll during your birthday month or one of the next three months, Part B generally starts the next month. Waiting can therefore create a period in which your Medicare and CHAMPVA status do not line up.
If you have employer coverage or another health plan, do not assume that it removes CHAMPVA's Part B requirement. CHAMPVA eligibility and Medicare enrollment rules are separate questions. If you are entitled to Part A and fall under the modern CHAMPVA rule, verify your Part B effective date before relying on CHAMPVA after age 65.
Which parts of Medicare matter for CHAMPVA?
| Medicare coverage | What it means for CHAMPVA |
|---|---|
| Part A | If you turn 65 now and are entitled to Part A, Part B is generally also required to keep CHAMPVA. |
| Part B | Required for most current age-65 CHAMPVA beneficiaries who are entitled to Part A. You must stay enrolled unless a specific grandfather exception applies. |
| Part C / Medicare Advantage | Current VA guidance says Medicare Advantage meets the requirement because it includes Medicare Part A and Part B benefits. The Medicare Advantage plan pays first and CHAMPVA is secondary. |
| Part D | Not required to establish or keep CHAMPVA eligibility. Prescription coverage still has its own coordination rules. |
The current VA CHAMPVA benefits page and CHAMPVA care guidance both state that beneficiaries who are eligible for Medicare generally need Part A and Part B to get or keep CHAMPVA.
What to send VA when your Medicare coverage starts
When your Medicare card arrives, confirm that the Medicare effective dates are correct and then update CHAMPVA promptly.
VA's current guidance tells enrolled beneficiaries to provide:
- a copy of the front and back of the Medicare card; and
- a completed CHAMPVA Other Health Insurance Certification, VA Form 10-7959C.
You can use the current VA Form 10-7959C page to submit the other-health-insurance update using the available VA process.
The CHAMPVA Guidebook specifically instructs beneficiaries to send the Medicare information as soon as the card is received so VA can update the record without an avoidable interruption.
If you have Medicare Part D, VA asks for the Part D card when you report other insurance, even though Part D is not required for CHAMPVA eligibility.
Medicare becomes primary and CHAMPVA becomes secondary
Once you have Medicare and CHAMPVA, Medicare is generally billed first. CHAMPVA then considers the remaining eligible amount after Medicare processes the claim.
In the ordinary Original Medicare workflow:
- the provider bills Medicare first;
- Medicare adjudicates the claim;
- Medicare may electronically forward the processed claim to CHAMPVA; and
- CHAMPVA considers the remaining covered amount under CHAMPVA rules.
If the claim does not cross over electronically, you or the provider may need to send CHAMPVA the primary payer's explanation of benefits and the required itemized billing information.
Having CHAMPVA as secondary coverage does not mean every Medicare balance is automatically payable. The service still has to satisfy CHAMPVA's own coverage rules, and other CHAMPVA requirements can still apply.
What if you have Medicare Advantage?
Current VA guidance says a Medicare Advantage plan meets the Medicare requirement for CHAMPVA. Medicare Advantage is still your primary coverage, so the plan's rules are applied first. CHAMPVA then acts as secondary payer for eligible remaining costs.
This matters when choosing providers. CHAMPVA itself does not use a medical provider network, but a Medicare Advantage plan may have network, referral, or authorization rules that apply because the Medicare Advantage plan is primary.
What if you also have Medigap?
If you have Original Medicare plus a Medicare supplemental policy, often called Medigap, the CHAMPVA Guidebook says CHAMPVA pays after the Medicare supplemental plan as well.
The payment order is generally:
Medicare → Medicare supplemental plan → CHAMPVA
You may need to submit the Medicare supplemental plan's explanation of benefits before CHAMPVA can process the remaining amount.
The June 5, 2001 grandfather rule
The current regulation preserves a narrow exception for beneficiaries whose Medicare status was already established before June 5, 2001.
Under 38 CFR § 17.271:
- a person who was already age 65 or older before June 5, 2001, was otherwise CHAMPVA-eligible, was entitled to Part A, and had not purchased Part B may remain eligible for CHAMPVA without Part B; but
- a person in that pre-June 5, 2001 group who had Part B must continue carrying Part B to retain CHAMPVA eligibility.
Anyone who reached age 65 on or after June 5, 2001, and is entitled to Part A falls under the rule requiring Part B.
Because this exception depends on old entitlement dates and Medicare history, beneficiaries who believe it applies should verify their record with VA rather than dropping Part B based only on the age of the rule.
If you are 65 or older and not entitled to premium-free Medicare Part A
Turning 65 does not automatically end CHAMPVA. The key question is your Medicare Part A entitlement, not simply whether you currently carry a Part A card.
Under 38 CFR § 17.271, an otherwise eligible person age 65 or older who is not entitled to Medicare Part A retains CHAMPVA eligibility. The regulation then explains what proof VA needs for several less-common Medicare statuses.
What is an SSA Notice of Disallowance?
If the Social Security Administration determines that you are not eligible for Medicare Part A, § 17.271 says an SSA Notice of Disallowance certifying that fact must be submitted. VA's current CHAMPVA benefits page says that for a person age 65 or older who does not qualify for Medicare, the notice confirms that the person does not qualify for Medicare benefits under anyone's Social Security number.
SSA's policy on disallowance notices describes a disallowance notice as the formal notice SSA sends after an initial determination disallowing a claim, including a claim for health insurance. For CHAMPVA purposes, the important point is that the notice is official evidence of SSA's determination. It is not a statement you write yourself, and it is not created merely because you would prefer not to enroll.
Premium-free Part A and Premium-HI are different statuses
The current CHAMPVA Guidebook describes Part A as premium-free hospital insurance and says that if you are over age 65 and were never eligible for premium-free Medicare Part A, you do not need Part B to keep CHAMPVA.
SSA also recognizes Premium Hospital Insurance (Premium-HI)—Part A that some people who cannot get Part A for free may be able to buy. SSA's current Medicare notice policy specifically distinguishes people who cannot get Part A for free from people who may be able to buy it.
CHAMPVA's regulation makes the documentation distinction explicit:
- If you are not eligible for Part A, submit the SSA Notice of Disallowance.
- If you are entitled to Part B only, but not Part A, provide your Medicare card or other official documentation showing that status.
- If you have Part A through the Premium-HI provisions, provide your Medicare card or other official documentation showing that status.
This is why the ability to buy Part A with a premium should not be treated as the same thing as entitlement to premium-free Part A when you are documenting CHAMPVA eligibility. Use the official SSA or Medicare determination rather than trying to infer your CHAMPVA status from the premium amount alone.
A Notice of Disallowance is not a way to opt out of Medicare
If you are actually entitled to Part A under the modern CHAMPVA rule, simply declining Part A or Part B does not create the exception for people who are not entitled to Part A. The rule is based on entitlement, and the Notice of Disallowance is evidence that SSA found you ineligible.
For someone who reaches age 65 on or after June 5, 2001 and is entitled to Part A, § 17.271 requires enrollment in Part B to retain CHAMPVA as secondary coverage. The Guidebook also warns beneficiaries not to cancel Part B without confirming that an exception applies.
What proof should you send VA?
Use the documentation that matches the Medicare status SSA has actually determined:
- No Part A eligibility: Submit the SSA Notice of Disallowance.
- Part B only, with no Part A: Submit the Medicare card or other official documentation showing that status.
- Part A through Premium-HI: Submit the Medicare card or other official documentation showing the Premium-HI status.
Keep a copy of what you send. If your Medicare record is unusual or the documents do not clearly show the status, resolve the Medicare determination with SSA and the CHAMPVA eligibility record with VA before changing existing coverage.
A practical age-65 checklist
About three months before your 65th birthday:
- confirm whether Medicare will enroll you automatically or whether you need to apply;
- make sure you understand your Part A entitlement and Part B effective date;
- if Part B is required for you, enroll early enough for it to be effective when needed.
When your Medicare card arrives:
- verify the Part A and Part B effective dates;
- keep a copy of the card;
- submit your Medicare information and VA Form 10-7959C to CHAMPVA.
After Medicare becomes effective:
- tell your medical providers that Medicare or your Medicare Advantage plan is primary and CHAMPVA is secondary;
- review your first few explanations of benefits to make sure the claims are crossing over correctly;
- keep Medicare, CHAMPVA, and any supplemental-plan information current with your providers and VA.
If your Medicare status is unusual—for example, you are not entitled to Part A, you believe the pre-June 5, 2001 rule applies, or your Medicare effective dates do not match what you expected—resolve the eligibility question with VA and Medicare before changing coverage.