Are you wondering if you still are required to provide HIPAA Certificates of Creditable Coverage? It seems unnecessary in light of the prohibition on applying pre-existing condition limitations (PCLs) starting in 2014; however because this prohibition applies to plans based on their plan year (rather than immediately on 1/1/2014), terminating individuals may still have a need for a HIPAA Certificate. So, all plans must continue to provide HIPAA Certificates until 12/31/2014.


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