TDI addresses this question on its website: https://www.tdi.texas.gov/health/faqs.html
Yes. Texas law (TIC §1205.002) requires carriers to continue issuing certificates of creditable coverage, “as necessary.” However, given the reduced need for these certificates, TDI will consider carriers in compliance if they provide certificates of creditable coverage upon request, consistent with 28 TAC §21.1103(b).