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The Health Insurance Portability and Accountability Act of 1996 (HIPAA)

Certificates of Creditable Coverage

A certificate of creditable coverage is a written certificate issued by a group health plan or health insurance issuer (including an HMO) that shows a participantís prior health coverage (creditable coverage).

Complete certificates of creditable coverage must be sent (free of charge) automatically to individuals whose coverage under the plan ends.

The certificate must be delivered:

  • To an individual who is entitled to elect COBRA, at a time no later than when a notice is required to be provided for a qualifying event under COBRA (usually not more than 44 days);
  • To an individual who loses coverage under the plan and who is not entitled to elect COBRA, within a reasonable time after coverage ceases; and
  • To an individual who ceases COBRA, within a reasonable time after the plan learns that COBRA has ceased.

Certificates must also be provided upon request to individuals (1) while covered under the plan and (2) for up to 24 months after coverage ends.

As per a HIPAA regulation, the certificate should reflect periods of continuous coverage that an individual had in the 24 months prior to the date of the request (up to 18 months of creditable coverage).

The plan should also have a written procedure for individuals to request and receive certificates of creditable coverage.

The Department has developed a model certificate that can be helpful. Correct use of the model will generally assure compliance with the regulatory requirements.

Responsibility for issuing these certificates may depend on whether or not your plan is insured.

Is your plan insured?