Processing Delays Transmittal No. We are continuing to gather information about this problem.
Issuers are also subject to certain requirements to furnish information to applicants.
If premium information is supplied properly, issuers operating in either market should not need to delay the processing of applications in order to finalize price quotes. In particular, an issuer must treat an individual as having furnished a certificate if he or she attests to the period of creditable coverage, presents relevant corroborating evidence of some creditable coverage during the period, and cooperates with the issuer's efforts to verify the individual's coverage. The effect of a significant break in coverage is different in the small group market, where guaranteed availability applies to the group as a whole, providing protection to small employers rather than to individual employees in the group. A plan is not required, however, to count as creditable any coverage that is followed by a significant break in coverage - i.e., at least 63 days. If a significant break were to occur due to an issuer's delay in processing an application for group coverage, then clearly members of that group could be disadvantaged.