ACA Impact on CoCC Requirements
The Affordable Care Act eliminated the use of pre-existing condition exclusions for individuals of all ages for plan years beginning on or after January 1, 2014. Group health plans and issuers, however, were required to continue to issue HIPAA Certificates of Creditable Coverage (CoCCs) for the duration of 2014 since a plan year can begin late in the calendar year (as late as December 31).
Elimination of CoCC for Terminating Members
Because 2014 will soon be coming to a close, generation of HIPAA Certificates of Creditable Coverage (CoCC) upon member termination will no longer be necessary because the pre-existing condition limitations are fully eliminated in 2015.
UnitedHealthcare is taking the following approaches to provide a smooth transition for customers and members:
- For self-funded customers, where we deliver HIPAA CoCC letters on their behalf, these letters will be discontinued as of Jan. 1, 2015. Member requests for ‘proof of lost coverage’ can be accommodated via our member call center.
- For fully insured customers, letters will still go out. The existing CoCC letters are being modified as of Jan. 1, 2015 to remove references to pre-ex and instead of communicating as a ‘certificate of creditable coverage’ the letter will communicate ‘proof of lost coverage’ – these notices will include applicable state mandate information.
CoCCs as Proof of Prior Coverage Still Available
It is important to note that the process to support ad-hoc member requests for ‘proof of current coverage’ on active members is not changed as part of this transition.
Some self-funded clients and large fully insured clients send their own HIPAA CoCCs. These clients may discontinue notices that are specifically for HIPAA portability purposes.