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HIPAA certificates no longer needed due to ACA

Over the years, there have been a number of changes to the Health Insurance Portability and Accountability Act.  One of these changes will take effect on January 1, 2015: Medical plans will no longer be required to provide Certificates of Creditable Coverage. As a result, Aetna will stop producing certificates at that time.  

As you know, the certificates showed that a person had previous creditable coverage in order to reduce pre-existing restrictions. But the landscape has changed.  The Affordable Care Act prohibits the use of pre-existing condition clauses for most types of coverage in plans renewed on or after January 1, 2014.  On February 24, 2014, the Treasury, the Department of Labor, and the Department of Health and Human Services jointly issued final regulations that eliminated the requirement for plan sponsors to issue the certificates after December 31, 2014.

Qualifying event documentation

While Certificates of Creditable Coverage served as proof of previous coverage for members with pre-existing conditions, they were not intended as supporting documentation of qualifying events and do not document the reason for policy termination.  It is the plan sponsors' responsibility to apply their eligibility rules with respect to qualifying events, and they typically require the prospective member to supply documentation proving the event occurred.

Documentation for qualifying events varies.  Below are a few examples of what may be considered appropriate documents.

If you have any questions, please contact your Aetna representative.

Qualifying event

Document examples

Marital status change

Marriage certificate, divorce certificate

Change in number of dependents

Birth certificate

Change in employment

Termination letter from employer



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