Late Certificates

[Guest calcu]

We have a situation where we terminated coverage for an individual retroactively. The person has now requested a certificate, however, it is well past the 63 days since the coverage was terminated. Any ideas on how to fix this?

[papogi]

You still have to provide the certificate. It's my understanding that group health plans subject to HIPAA have to provide certs upon request within 24 months of losing coverage. There is no 63 day provision. That comes into play when calculating creditable coverage days when applying a pre-ex provision for the next carrier. HIPAA requires that you send out the first cert without any request, and you can document that you had the cert out as fast as you could (the termination was retroactive).