Joe, What do you mean, "suppress the HIPAA certificates of creditable coverage if requested".  Suppress by whom, from whom?

They are not PHI, as they go from employer to employer, or from employer to employee to employer.  The employee could certainly suppress it, by not forwarding it.  The old employer cannot suppress it, as it is a federal requirement to provide the employee with the letter.  The new employer cannot reject it, as it could cause the employee irreparable harm, insurance red lining.

Does this help?

Errick Woosley, MPA
E Woosley & Assoc
(513) 218-7436
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