Will HIPAA's Model Certificate of Creditable Coverage Be Revised
Areas of concern.
According to the GAO, the model certificates are deficient in several areas. For example, the certificate fails to inform participants that once they leave the group market:
- They may have a right to obtain health insurance in the individual market.
- If they accept other employment, they might not have to fulfill a preexisting condition period under the new employer's group health plan.
The GAO has made several recommendations for retooling the certificate to better educate the health plan consumer, and the DOL and the Health Care Financing Administration have generally agreed with the GAO's recommendations. Therefore, it wouldn't be surprising to see some changes in the model certificate when final regulations are released. (Currently, the GAO notes that officials expect to finalize HIPAA regulations in 2000.)
What should employers do?
Employers wishing to stay ahead of the game should consider revising their certificates to incorporate some of the GAO's recommendations. Specifically, the GAO recommends that the following information be highlighted:
- The rules relating to preexisting conditions and the guaranteed renewability of health coverage.
- The prohibition against discrimination against an insured on the basis of that individual's health status.
- The right to guaranteed access to insurance for individuals losing group coverage.
In addition, the GAO strongly recommends that the certificates inform participants whom they should contact for further information about their rights under HIPAA. Adding this information to the certificate should take plan administrators little time and, in the long run, may actually save time, since employees will be better informed and may have less need to contact plan administrators for further information after employment is terminated.
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