In our December, 4, 2014 blog Health Care Alert: HIPAA Certificates of Creditable Coverage Changes for 2015 we advised our readers that HIPAA Certificates of Creditable Coverage (CoCC) upon member termination, will no longer be necessary because the pre-existing condition limitations have been fully eliminated in 2015. Per the IRS Bulletin 2014-11, Section 54.9801-5, the IRS has confirmed that this provision was effective on 1/1/15.
Certificate of Coverage May Still Be Needed After 1/1/15
While the provision took effect on 1/1/15, the certificate (CoCC) may still be needed in certain situations (proof of lost coverage, grandfathered plans, enrollment in the Health Insurance Marketplace outside of open enrollment, etc.).
Member Requests for Proof of Lost Coverage, CoCC Letters, and HIPAA Portability Letter
Member requests for ‘proof of lost coverage’ can still be accommodated by most insurance carriers via their Member Services Departments. Most of the existing CoCC letters are being modified as of January 1, 2015 to remove references to pre-existing conditions, and instead of communicating as a ‘certificate of creditable coverage’ or ‘HIPAA portability letter’, the letter will communicate ‘proof of lost coverage’ and the notices will include applicable state mandate information.
Do you need assistance with your HIPAA communication?
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