Mr. Giles attained age 65 in January 2010. Mr. Giles refused SMI because of GHP coverage
provided through the union’s Welfare Fund. The premiums for the GHP coverage were
paid out of the Reserve of Contributions Account. In March 2014, the union advised
Mr. Giles that the hours’ at the bank would end on May 31, 2014.
Under the SEP provisions, Mr. Giles can enroll in SMI any month that the GHP coverage
is funded via the Reserve of Contributions Account or during the 8-month period beginning
June 2014 (the first month Mr. Giles no longer has the hours’ bank arrangement). The
premium surcharge calculation excludes any months Mr. Giles was currently employed
with GHP coverage and continued coverage under the hours’ bank arrangement.