This Advisory Bulletin does not address the amendments contained in those subchapters. The coverages identified in the definition are very broad and include coverage issued in the insured market, various government programs, as well as self-funded plans.
Creditable coverage includes plans that are issued outside the United States.
Carriers may require whatever reasonable documentation may be necessary to establish whether an employee is a bona-fide employee. The change allows, but does not require, carriers to accept evidence of full-time employee status using documentation other than pay records. The enrollment date is defined as the date of enrollment in the health benefits plan, or the first day of the waiting period for such enrollment, if earlier. For example, assume a small employer with 3 employees has a plan with a 3-month waiting period. On November 1 the employer hires a new employee, who was uninsured for the prior 4 months.