You're half right. The 2025 update to the creditable coverage guidance made it so plans have to wait until CMS approves the enrollment before the attestation request letter can be sent out. Obviously, in this case that time has come and gone a while ago.
But also you're half right in a different way. Plans would submit the enrollment reporting no gap, but if there was a possible gap then the attestation request goes out. If a response is received that accounts for all months then it stays at no gap. But say the plan figured 12 months with no prior CC and no response is received then that 12 months is what the LEP will be based on.
But also you're half right in a different way. Plans would submit the enrollment reporting no gap, but if there was a possible gap then the attestation request goes out. If a response is received that accounts for all months then it stays at no gap. But say the plan figured 12 months with no prior CC and no response is received then that 12 months is what the LEP will be based on.