A&H Policy ProvisionsQuestion 256 of 315

Under HIPAA's portability rules as modified by the ACA, which statement is correct regarding pre-existing condition exclusions in group health plans?

a.Group plans may exclude pre-existing conditions for up to 12 months
b.Group plans may exclude pre-existing conditions for up to 18 months for late enrollees
c.Pre-existing condition exclusions are no longer permitted in any non-grandfathered group or individual health plan
d.Pre-existing condition exclusions are permitted only for participants over age 65

Explanation

Originally, HIPAA Title I (29 U.S.C. §1181) permitted group health plans to impose a pre-existing condition exclusion of up to 12 months (18 months for late enrollees), reduced by prior 'creditable coverage' under a HIPAA certificate. However, the Affordable Care Act effectively eliminated pre-existing condition exclusions: §2704 of the Public Health Service Act, added by the ACA, prohibits ANY pre-existing condition exclusion in non-grandfathered individual and group health plans. Options A and B describe the pre-ACA HIPAA rule, which has been superseded. Option D is fabricated. Today, both Covered California and employer group plans must accept enrollees regardless of pre-existing conditions; California Insurance Code §10198.7 mirrors this protection at the state level.

Law Reference: 29 U.S.C. §1181 (HIPAA Title I portability)

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