On February 24, 2014, the United States Departments of Health and Human Services issued a final rule that addressed the requirement to provide HIPAA Certificates of Creditable Coverage (HIPAA Certificates) under the Affordable Care Act (ACA). As the ACA prohibits pre-existing condition exclusions, the new rule eliminates the requirement to provide HIPAA Certificates beginning December 31, 2014.
What does this mean for members? Previously, when coverage was terminated for a member or his/her dependents, Independence Blue Cross (Independence) issued a HIPAA Certificate. Because the ACA prohibits the application of pre-existing condition exclusions, which applies to both grandfathered and non-grandfathered health plans, these certificates are no longer required.
Effective January, 1, 2015, Independence will no longer issue them to individual or group members. Notifications of coverage changes (e.g. terminations) to government program members, which are made by CMS-approved letters rather than HIPAA Certificates, will continue. For additional information, please see the IRS notice (Section II. Overview of the Final Regulations; B. Conforming Changes to Existing Regulations). If you have questions, please contact your Total Benefit Solutions account manager at (215)355-2121.