HIPPA Notices and Severance Agreements

[Guest ABRAHAM]

Hi, a good question was posed to me today regarding HIPPA noices that I hadn't thought about. I have an employee who terminated from my company on 4/10/99. As part of a severance agreement, however, my company agreed to pick up the cost of COBRA until 10/10/99. This former employee has now requested a HIPPA notice. Shoud we use the coverage end date of 04/10/99 or 10/10/99?

Thanks in advance!

[Guest JDH]

Abraham, because coverage has been continuous, you can send a certificate of creditable coverage now with a coverage end-date of 10/10/99. If the former employee and/or any of his/her dependent(s) should continue COBRA coverage, you should send another certificate when COBRA ends.