Required to keep a copy of the certificates?

[Guest]

Are plan administrators/employers required to keep copies of the certificates of creditable coverage or would a log be enough?

[Guest Damien]

I would recommend keeping a copy, since you will also be required to produce it again if the member requests one at any time in the 24 months following the loss of coverage. In my experience, repeat requests are frequent since people misplace them or throw them out not realizing what they are.

[Kirk Maldonado]

Do the HIPAA regulations provide any guidance? Is there any guidance under he general ERISA record retention rules?

[Guest Damien]

Having looked through the HIPAA regs, I can only find wording (sec 701) on what is required to be supplied to the plan member, nothing on the form of records the administrator must maintain.

Could you point me to the area of the ERISA law covering record retention? I am not sure where to begin looking, but would like to check it out. Thanks.

[Kirk Maldonado]

ERISA Section 209.