Are plans and issuers required to issue certificates of creditable coverage to dependents of covered employees?
Yes. A plan or issuer must make reasonable efforts to collect the necessary information for dependents and issue the dependent a certificate of creditable coverage. If the coverage information for a dependent is the same as for the employee, one certificate with both the employee and dependent information can be provided. However, an automatic certificate for a dependent is not required to be issued until the plan or issuer knows (or, making reasonable efforts, should know) of the dependent’s loss of coverage. This information can be collected annually, such as during an open enrollment period.