Mr. Giles attained age 65 in January 2010. He refused SMI because he had GHP coverage
provided through his union’s Welfare Fund. The premiums for the GHP coverage were
paid out of his Reserve of Contributions Account. In March 2014, the union advised
Mr. Giles that his hours’ bank arrangement would end on May 31, 2014.
Under the SEP provisions, Mr. Giles can enroll in SMI any month that his GHP coverage
is funded via his Reserve of Contributions Account or during the 8-month period beginning
June 2014 (the first month he 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.