HIPAA certificates no longer needed due to ACA

Starting January 1, 2015, medical plans will no longer be required to provide Certificates of Creditable Coverage (COCCs) under the Health Insurance Portability and Accountability Act (HIPAA). As a result, medical insurers will stop producing and sending COCCs as of the 1st of the year.

These certificates, also sometimes referred to as ‘HIPAA Certificates’ served to show that a person had previous creditable coverage in order to reduce pre-existing restrictions; since the Affordable Care Act (ACA) prohibits the use of pre-existing condition clauses for most types of coverage in plans renewed or initiated in 2014, on 2/14/14 the Treasury, the Department of Labor, and the Department of Health and Human Services jointly issued final regulations that eliminated the requirement for plan sponsors to issue the certificates after December 31, 2014.

Qualifying event documentation

While COCCs served as proof of previous coverage for members with pre-existing conditions, they were not intended as supporting documentation of qualifying events and did not document the reason for policy termination.  It is the plan sponsors’ responsibility to apply their eligibility rules with respect to qualifying events, and they typically require the prospective member to supply documentation proving the event occurred.

Documentation for qualifying events varies.  Below are a few examples of what may be considered appropriate documents:


Qualifying event Document examples
Adding a dependent Birth certificate, adoption agreement
Change in employment Termination letter from employer
Loss of coverage through spouse Letter from spouse’s employer
Loss of coverage under COBRA, Continuation Letter from former employer
Marital status change Marriage certificate, divorce certificate