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In the HIPAA regs issued on 12/30/2004, the preamble discusses the requirement for certain entities who are not otherwise subject to HIPAA to provide certificates of creditable coverage (related to PCL). This included Medicare, Medicaid, Tricare, etc. The preamble states that the unique manner in which these programs operate necessitate implementing the HIPAA certificate requirement differently and that HHS would be issuing separate guidance. Did that ever happen? I can't find anything explaining how the HIPAA certificate requirement applies to plans such as Medicare Advantage which can be issued on a group basis through employers. Can anyone help direct me? Thanks!

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