Human Resources
Proposed Regulations Implement 90-Day Waiting Period and End HIPAA Creditable Coverage Certificates

Proposed Regulations Implement 90-Day Waiting Period and End HIPAA Creditable Coverage Certificates


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Grandfathered and non-grandfathered group health plans and health insurance issuers may not impose any waiting period that exceeds 90 days, for plan years beginning on or after January 1, 2014, according to proposed regulations issued March 18, 2013 by the Departments of Labor, Health and Human Services, and Treasury. In addition, the proposed regulations provide that for plan years beginning after 2014, the Patient Protection and Affordable Care Act’s (Affordable Care Act) prohibition on pre-existing condition exclusions would supersede the HIPAA creditable coverage rules, with the result that group health plans would no longer have to issue certificates of creditable coverage to participants and beneficiaries who lose health care coverage. The Aon Hewitt bulletin below describes the impact of these regulations on employer group health plans.

Download Proposed Regulations Implement 90-Day Waiting Period and End HIPAA Creditable Coverage Certificates