Many people confuse the ESRD waiting period with the ESRD MSP coordination period. While both affect how long a GHP must pay as the primary payer for employees with ESRD, they are not interchangeable and it is important to understand the difference when discussing COB for beneficiaries entitled to Medicare on the basis of ESRD.

The ESRD Waiting Period

The ESRD waiting period is generally three months long, but can be waived or shortened if a beneficiary participates in a self-dialysis training program or is scheduled for an early kidney transplant respectively.

The waiting period is waived if self-dialysis training occurs within the first three months of the start of maintenance dialysis. The waiting period is shortened to the first of the month in which the patient is hospitalized for transplantation, provided the surgery takes place in that month or the following two months.

Generally people do not have entitlement to Medicare during the ESRD waiting period (we'll discuss dual entitlement later). Medicare is neither Medicare primary nor Medicare secondary during this time period. The person does not have Medicare.

It would be as if you left your current job to work for XYZ Inc. where you had to wait until you had six months of service for the new employer to cover you under their insurance. XYZ Inc. insurance is not primary or secondary to any other insurance you might have because you are not entitled to the XYZ Inc. insurance yet.

For the purposes of this document we will assume no self-dialysis training or early transplants occurred to make issues and examples less confusing. However, please keep in mind that you need to allow for the possibility of shortened waiting periods in your everyday work.

The ESRD MSP Coordination Period

The ESRD MSP coordination period is generally 30 months long and occurs after the ESRD waiting period Definitively, the ESRD MSP coordination period begins on the date that Medicare became effective or would have become effective on the basis of ESRD. This is a very important phrase to remember when dealing with beneficiaries who do not sign up for Medicare when they could/should have, and in dual entitlement situations.

During that 30-month coordination period, Medicare pays as the secondary payer and the GHP pays as the primary payer. After the 30 months, the roles reverse, and Medicare pays as the primary payer while the GHP pays as the secondary or supplemental payer.