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HIPAA and college-sponsored plans


Guest Bob Gutowski

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Guest Bob Gutowski

I have a general question about HIPAA and college-sponsored health plans.

First, my understanding is that college plans are deemed "bona fide associations" and as such the individual markets rules under HIPAA apply. Is this correct?

If so, what are the ramifications in terms of creditable coverage in each of these situations:

(i) If someone moves from a group plan to a college sponsored plan, must the college sponosred plan apply the creditable coverage from the group plan?

(ii) If someone changes colleges and moves from one college-sponsored plan to another, must the second plan apply the creditable coverage from the first?

(iii) If someone moves from a college-sponsored plan to a group plan, must the group plan apply the creditable coverage against any pre-existing condition exclusion period?

Thanks very much.

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Rob Gutowski

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