Approved for use through 12/99 which OMB expects will be close to the publication date of the final rule. The resubmission must: 1) thoroughly address the OMB clearance remarks dated 5/30/97; and 2) reestimate the burden of these requirements based on the Department's actual implementation and enforcement experience. Most important, HHS, DoL, and Treasury must not adopt as a prece- dent the current burden estimate for certificates of credible coverage. The next burden estimate for these requirements must be rationally coordinated between the Departments and should be based upon "zero-based", unbiased analysis.
Inventory as of this Action
Requested
Previously Approved
12/31/1999
12/31/1999
03/31/1998
8,000,000
0
9,000,000
336,060
0
251,000
31,800,000
0
34,240,000
In order to meet HIPAA's goal of improving access to and portability of health care benefits, the statute provides that, after the submission of evidence establishing prior creditable coverage, a subsequent health insurance provider would be limited in the extent to which it could use preexisting condition exclusions to limit coverage. Pursuant to the Department's implementing rules at 29 CFR 2590.701-5, this ICR covers the submission of materials sufficient to establish prior creditable coverage.
On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).
The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control number;
If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.