Certificate of Creditable Coverage

A certificate of creditable coverage (COCC) is a document provided by your prior insurer that indicates your insurance has ended. The document itself includes your full name, effective dates of coverage, and the cancellation date. The COCC was created under the Health Insurance Portability and Accountability Act (HIPAA), which ensures that those who want to change health insurance carriers can do so without having a gap in medical insurance. Such a document applies when a person joins a new company, and wishes to enroll in the employer-sponsored health insurance plan. Without HIPAA, those people enrolling in the new coverage may have to wait a period of time before enrolling, which would mean that the prior health insurance would end before the new one begins. However, under HIPAA laws, such gap is not allowed.

The specific provision set forth in the HIPAA laws provides that once you have been continually insured for a period of at least 18 months, then there is no need to satisfy another waiting period before enrolling in a new healthcare plan. While many health plans require 18 months of continuous coverage, some healthcare policies provide only six months of continuous coverage. A gap in health insurance coverage of less than 60 days doesn’t place a risk on the “continuous coverage” rule; however, you should ensure that you maintain a short-term medical insurance plan if the gap is going to last for more than 60 days.

Benefits of the COCC

  • The COCC program is an automated program providing much less effort for insured individuals
  • The certificate itself is generated automatically by all insurance companies within a couple of weeks after the coverage term ends.
  • If you don’t receive a certificate by mail within 30 days of termination, you’ll want to contact the insurance company and verify your mailing address.
  • Some health insurance companies are now delivering the certificate online over the Internet or via e-mail, which is a much quicker method than mailing the documents.
  • If you are in between jobs, the certificate is available from the COBRA plan administrator or the administrator of a short-term medical insurance company, whichever type of coverage you choose to have while unemployed.
  • Keep in mind that not all health insurance companies provide such certificates. For example, supplemental, foreign, and international travel insurance plans don’t provide a COCC.
  • After you receive a COCC, you’ll want to immediately forward it to your new health insurance company, while also keeping a copy for your records.

Coverage for Pre-existing Conditions

A COCC is not useful for obtaining coverage if you have a pre-existing condition and the new health insurance company doesn’t provide coverage for the pre-existing condition, i.e. short-term medical insurance policy. In addition, you should be mindful that most of the lower priced health insurance policies do not provide for coverage of pre-existing conditions. In fact, a common misconception for most is that they can easily terminate one health insurance policy and easily obtain coverage on the new insurance policy. However, most health insurance providers have certain eligibility requirements that must be met, and those with prior health issues could be denied coverage. However, if the new health insurance coverage is an employer-sponsored policy, this would not be the case.

COCC Federal vs. State Laws

The federal law regarding COCC is different from that of state laws, which are implemented to address the underlying issues regarding take-over benefits and the eligibility requirements for obtaining health insurance. While the federal law trumps state laws if any conflicts in the rules arise, the states have complete control over health insurance plans within their jurisdiction, i.e. some states do not recognize COCC from someone’s health insurance as a valid entry into a state-sponsored high-risk health insurance plan.

Regulations Eliminating the COCC

A new regulation on Exchange and Insurance Market Standards for 2015 and Beyond was published by the U.S. Department of Health and Human Services (HHS) confirm that certain states can terminate the issuance of the COCC, and even allow those with pre-existing health conditions to obtain insurance more easily. Therefore, as of January 1, 2015, most health insurance plans no longer contain pre-existing conditions, particularly due to the implementation of the Patient Protection and Affordable Care Act (PPACA). The main purpose of providing the COCC was to protect employees that change to a new plan and need proof of prior coverage. With the regulation eliminating the COCC, it allows those to further reduce any waiting periods, health exclusions, and other pre-existing condition exclusions that could prevent those from obtaining health insurance with a different insurance carrier. With that being said, however, some health insurance policies still contain pre-existing condition exclusions that could prevent those falling in this category from obtaining coverage.

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