Is there another way that a group health plan or issuer can credit coverage under HIPAA?

Yes.  A plan or issuer may elect the alternative method for crediting coverage for all employees.

Under the alternative method of counting creditable coverage, the plan or issuer determines the amount of an individual's creditable coverage for any of the five specified categories of benefits.  Those categories are mental health, substance abuse treatment, prescription drugs, dental care and vision care.  The standard method is used to determine an individual's creditable coverage for benefits that are not within any of the five categories that a plan or issuer may use.  (The plan or issuer may use some or all of these categories.)

When using the alternative method, the plan or issuer looks to see is an individual has coverage within a category of benefits (regardless of the specific level of benefits provided within that category).

For example, if an individual who is a regular enrollee (not a late enrollee) has 12 months of creditable coverage, but coverage for only 6 of those months provided benefits for dental care, a preexisting condition exclusion period may be imposed with respect to that individual's dental care benefits for up to 6 months (irrespective of the level of dental care benefits).

If your employer's plan requests information from your former plan regarding any of the five categories of benefits under the alternative method, your former plan must provide the information regarding coverage under the categories of benefits.