By: Lois Mathis-Gleason, CEBS
The Affordable Care Act (ACA) gave health plans an extraordinary amount of new reporting and disclosure requirements. However, one preexisting requirement (pun intended) will disappear beginning January 1, 2015: The HIPAA Certificate of Creditable Coverage.
Health plans had to provide these certificates to individuals losing health coverage so the individuals could prove they had creditable health coverage, reducing or eliminating any preexisting condition exclusion periods in the next health plan they joined. Starting with plan years beginning on or after January 1, 2014, the ACA prohibited preexisting exclusion periods for all health plans (grandfathered and nongrandfathered). As a result, no certificates of creditable coverage need to be issued on or after December 31, 2014.
[Related: Watch for new ACA FAQs added weekly in ACA University]
Health plans should continue providing these certificates to individuals whose coverage terminates before December 31, 2014, in case anyone needs to offset a preexisting condition exclusion when joining a noncalendar health plan during a plan year that began before January 1, 2014.
So, at your 2014 New Year’s Eve party, feel free to sing “Auld Lang Syne” to HIPAA certificates of creditable coverage, thanks to the Affordable Care Act! (But don’t forget to usher in that pesky “Play or Pay” employer mandate along with the 2015 new year.)
Note: Employers may need to provide proof of coverage and ending date for employees over age 65 (or disabled and under 65) who delayed enrolling in Medicare Part B so they can avoid penalties when they do enroll.
For purposes of Medicare drug coverage (Medicare Part D), employers must continue notifying Medicare eligible policyholders whether their prescription drug coverage is creditable coverage, which means that the coverage is expected to pay on average as much as the standard Medicare prescription drug coverage. See the CMS web page on Creditable Coverage for more information.
Ninety-Day Waiting Period Limitation and Technical Amendments to Certain Health Coverage Requirements Under the Affordable Care Act, Final Rule, Federal Register, February 24, 2014