Proposed regulations issued under the Affordable Care Act would eliminate the requirement to provide a HIPAA Certificate of Creditable Coverage when a participant terminates coverage under a group health plan. A group health plan or health insurance issuer provides a certificate of creditable coverage to a participant to document the duration of a participant’s health coverage. Presently, a certificate must be issued when coverage is lost under a group health plan, when an individual is entitled to elect COBRA continuation coverage, and when COBRA coverage ends. The certificate shows the individual’s most recent period of creditable health coverage.
Before health care reform, plans could impose pre-existing condition limitations on new enrollees. Prior creditable coverage could off-set a pre-existing condition limitation. Participants documented prior creditable coverage by producing a HIPAA certificate.