I have created a course in Moodle 2.9.1 with certificate version 2015012000 and set it so the certificate requires 5 minutes in the course before it will unlock. I enrolled a test student and logged in as the test student, went into my course and waited. After 15-20 minutes the certificate still says "You must spend at least a minimum of 5 minutes in the course before you can access this certificate"