Certificates of Creditable Coverage No Longer Required Beginning December 31, 2014
Final Rules Eliminate Requirement to Provide Certificates of Creditable Coverage
Final rules have been issued to amend provisions of the federal Health Insurance Portability and Accountability Act (HIPAA) that have become superseded as a result of Health Care Reform, including the requirement that group health plans issue certificates of creditable coverage.
For plan years beginning prior to January 1, 2014, HIPAA allows group health plans to exclude coverage for certain “pre-existing conditions” that are present before an individual’s first day of coverage under the plan (subject to limitations). As a result, group health plans have been required to issue certificates of creditable coverage demonstrating an insured’s prior period of health coverage that can be credited against any pre-existing condition period.
For plan years beginning on or after January 1, 2014, insurers are prohibited from imposing pre-existing condition exclusions under the Affordable Care Act, making certificates of creditable coverage unnecessary (the prohibition on preexisting condition exclusions has been in effect for children under 19 years of age since 2010).
Accordingly, final rules eliminate the requirement to issue certificates of creditable coverage beginning December 31, 2014. The effective date accounts for individuals needing to offset a pre-existing condition exclusion under plans beginning December 31, 2013, so that they will still have access to the certificate for proof of coverage through December 30, 2014.