The term "creditable
coverage" and the resulting document titled
Certificate of Creditable Coverage are the
products of the Health Insurance Portability
and Accountability Act (HIPPA) of 1996.
HIPAA was originally sponsored by Sen.
Edward Kennedy (D-Mass) and Sen. Nancy
Kassebaum (R-Kan) and is comprised of two
sections – Title 1 and Title II. Title I of
HIPAA protects health insurance coverage for
insured members and their families when they
change or lose health insurance coverage.
Title II, known as the Administrative
Simplification (AS) provisions, requires the
establishment of national standards for
electronic health care transactions.
The term "creditable
coverage" is the coverage requirement in
order for an individual to realize a
reduction in the exclusion period placed on
benefits when enrolling in a new health
insurance plan. Health insurance plans may
restrict benefits relating to a preexisting
condition for a period of up to 12 months
after enrollment in the plan. However, if
the individual has maintained creditable
coverage prior to enrolling in the plan and
did not experience a "significant break" in
coverage, the exclusion period may be
reduced or eliminated. "Creditable coverage"
is defined quite broadly and includes nearly
all group and individual health plans,
Medicare, and Medicaid. Short-term or
temporary health insurance coverage
typically does not meet the requirement of
"creditable coverage", although some
carriers will accept short-term coverage as
"creditable coverage."
A "significant break" in
coverage is defined as any 63-day period
without any creditable coverage. A gap in
coverage of less than 63 days does not
jeopardize the "continuous coverage," but it
is important to maintain a short-term health
insurance policy if there is going to be a
gap between two health plans.
The Certificate of
Creditable Coverage is the accepted
documentation in order to confirm an
individual’s prior health insurance
coverage. A Certificate of Creditable
Coverage indicates each individual who was
covered by the health plan and the length of
time each individual was continuously
covered under the health plan.
A common misunderstanding
regarding the purpose of a Certificate of
Creditable Coverage is that the document
qualifies an individual for guaranteed issue
coverage with full access to benefits
related to a preexisting condition. The
Certificate cannot fulfill this purpose
because individual health insurance plans
are subject to medical underwriting which
may establish eligibility requirements
excluding individuals with prior health
issues. The Certificate of Creditable
Coverage also does not eliminate or
reduce a rider assigned to coverage that
deals with a specific health condition. A
rider is either a permanent or temporary
waiver of benefits related to a specific
health condition. A rider is an alteration
of an insurance contract between the insured
member and the insurance carrier. The
Certificate of Creditable Coverage does not
nullify the rider assigned to the coverage.
Certificates of Creditable
Coverage are generated by the health
insurance carrier after the termination date
of coverage. When you receive a Certificate
of Creditable Coverage be sure to check the
document for accuracy. Individuals covered
by the health plan should be listed with the
start date and stop date of coverage
included.
To illustrate the
application of the Certificate of Creditable
Coverage, assume an individual enrolls in a
health plan on January 1, 2010. The
individual was previously insured under
another plan from January 1, 2009 until
February 1, 2009 and from August 1, 2009
until December 31, 2009. To determine the
value of the creditable coverage and how
much prior coverage can be credited against
the exclusion period in the new plan, start
at the enrollment date and count backwards
until you reach a significant break or gap
in coverage. Counting backwards would result
in five months of coverage between August 1,
2009 and December 31, 2009, which would
reduce the exclusion period by the same
number of months. But a gap in coverage was
experienced between February 1, 2009 and
August 1, 2009 of greater than 63 days.
Because the gap in coverage is greater than
63 days and would meet the definition of a
"significant break" in coverage, no coverage
prior to it can be used to reduce the
exclusion period. The covered individual
could deduct five months from the exclusion
period, reducing the exclusion period to
seven months.
The Certificate of Creditable Coverage
should not be overlooked, because it serves
an important administrative function to
document your prior coverage. If you have
questions concerning the Certificate of
Creditable Coverage contact Stateside
Insurance Services or the carrier
responsible for providing you with the
Certificate of Creditable Coverage.