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Certificates of Creditable Coverage

A "Certificate of Prior Creditable Coverage" (COPCC) was created by HIPAA so that individuals who change health insurance plans will have continuous coverage for ongoing medical conditions. A Certificate of Creditable Coverage only applies when a person is joining a new employer-sponsored group health insurance plan or possibly when enrolling in a state-assisted plan. The certificate does not apply to individual health insurance plans.

Without a Certificates of Creditable Coverage, new enrollees in a health plan might be subject to another  waiting period before coverage is offered for pre-existing medical conditions. This could discourage employees from changing jobs.

Health insurance programs counting as creditable coverage:

  • Group Health Insurance
  • Children’s Health Insurance Programs                            
  • Federal Employees Health Benefits (FEHBP)                 
  • Foreign National Coverage                                             
  • Group health plan (including COBRA) 
  • Indian Health Service                                     
  • Individual health insurance                         
  • Medicaid 
  • Medicare 
  • Military health coverage  (CHAMPUS, TRICARE) 
  • State high-risk pools 
  • Student Health Insurance 
  • VA Coverage
The certificate should contain:
  • The dates on which your prior health plan coverage began and ended (he most recent period of continuous coverage).
  • Contact information so that old and new plans can be in touch if necessary.
  • Information about your HIPAA rights.
  • The dates should be within the last 24 months but does not have to reflect more than 18 months of continuous health coverage (the longest possible preexisting condition exclusion period) without a significant break.

Continuously Insured Time Limit

The Certificate of Creditable Coverage provides that once you have been continuously insured for at least 18 months there is no need to spend time on another waiting period when you change group health insurance. 18 months is the maximum length of a waiting period but some group health plans have waiting periods of 3-6 months. A gap in coverage of less than 60 days does not jeopardize the "continuous coverage" but it is important to maintain a short term medical insurance plan if there is going to be a gap of more than two months between group health insurance plans.

Issuing a Certificate of Creditable Coverage

If you are in between jobs, a Certificate of Creditable coverage is available from the group health plan administrator. Some types of group insurance plans (like limited indemnity plans) do not provide a Certificate of Creditable Coverage.

The Certificate of Creditable Coverage program is mostly automated and can be automatically generated after a member's plan termination. If you do not receive a Certificate by mail within 30 days of termination, contact the insurer and make sure they have your verify your current mailing address. More Health insurers are delivering Certificates through email and Internet.

When you receive a Certificate of Creditable Coverage from the old insurer, check it for accuracy. It must include the name of each person covered under the former policy, along with the starting and ending date of coverage. You cannot obtain a Certificate before the termination date of your former insurance. Simply forward a copy to your new health insurance company. Keep a copy for our own records. Store the certificate with the new health insurance policy.

Limitations of Certificates

Certificates of Creditable Coverage are not useful for the purpose of obtaining coverage for pre-existing conditions when enrolling in a health plan that never offers a particular benefit (such as maternity) to anyone. Short term medical insurance plans also never cover pre-existing medical conditions. Most of the lower cost individual health insurance plans also never cover pre-existing medical conditions, even if you have a certificate. Most health insurance plans for individuals (as opposed to employer-provider group coverage) have eligibility requirements that preclude individuals with prior health problems.

Certificates of Creditable Coverage are available, but not necessary, when an entire business changes health insurance because the new group health insurance is issued with full takeover benefits for all eligible members enrolled on the date that the new insurance starts.

Portability Law Conflicts

Federal law regarding Certificates of Creditable Coverage are separate from state laws addressing transferring benefits and eligibility for group health insurance. Federal benefit laws may override state laws if there is a direct conflict, states usually have complete control for health insurance plans within their jurisdiction.

Some states do not recognize Certificates of Creditable Coverage from individual health insurance as valid for entry into state high risk pools. These enrolling members are still subject to additional waiting periods or exclusions for some benefits.

If you do not get a certificate

If your new plan imposes a preexisting condition exclusion, your claims processing will go smoother if you don’t delay and get your certificate. There are other ways to show you had creditable coverage with evidence of your prior health coverage which can include:

  • Pay stubs that reflect a deduction for health coverage premiums;

  • Copies of premium payments or other documents showing evidence of coverage;

  • Explanation of benefit forms; and

  • Verification by a doctor or your former health plan.

You may also be asked to attest to the period of creditable coverage and cooperate with the new plan’s reasonable efforts to verify you had creditable coverage.

Don't stop writing to the former plan's administrator to get a certificate for your records. The administrator’s contact information is should be in the info you received when you signed up for the health care plan.

Written by Craig J. Casey

Craig Casey is an Writer, Coach, Blogger, Husband, and Former Health Insurance Agent helping people on the web since 1999 with their health insurance problems.

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