"[G]eneration of HIPAA Certificates of Creditable Coverage (CoCC) upon member termination will no longer be necessary because the pre-existing condition limitations are fully eliminated in 2015."
Since 1997, group plans have had to issue Certificates of Creditable Coverage when a covered employee (and/or dependent) dropped off. They were essentially "hall passes" to the next group plan, so that one wasn't subject to pre-existing condition limitations.
[ed: Contrary to popular belief, they were of no avail when moving from group to individual plans - but were applicable when moving from individual to group. Clear as mud, no?]
These cert's have been part of the landscape for so long now that it just didn't occur to me that, once the ObamaTax is in full swing, they're no longer necessary.
Think I'll miss the little buggers.