Tuesday December 16th, 2014
HIPAA certificates of creditable coverage have served workers well to prove they have had health coverage and may be exempt from exclusions when changing health coverage. But as the saying goes, all good things must come to an end.
The Affordable Care Act (ACA) proposed eliminating these certificates as the one of ACA requirements was that preexisting condition clauses could not be enforced for plan years beginning on or after January 1, 2014. Final regulations confirmed the requirement for HIPAA certificates of creditable coverage ends as of December 31, 2014.
This has a two-fold effect. Preexisting condition exclusions are no longer in effect, but it also eliminates the need for HIPAA certificates of creditable coverage. This is effective for all participants and dependents, regardless of the participant’s age or the grandfathered status of the plan.
Until year end, HIPAA certificates are required to be provided as individuals may need to offset a preexisting condition exclusion under a non-calendar year plan.
As a result of the final regulations, Infinisource will no longer send HIPAA certificates effective January 1, 2015. If there is a loss of coverage in December (or before) requiring a HIPAA certificate, it is recommended those be reported to Infinisource prior to December 31 to ensure notification.