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Comments to the Centers for Medicare & Medicaid Services on Subsidized Graduate Student Health Insurance Plans

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Comments to the Centers for Medicare & Medicaid Services on Subsidized Graduate Student Health Insurance Plans

July 12, 2017

​Comments to the Centers for Medicare and Medicaid Services in response to a request for information on reducing regulatory burdens imposed by the Affordable Care Act. 

The focus of the association’s comments is the guidance issued in February 2016 by the departments of Treasury, Health and Human Services, and Labor prohibiting colleges and universities from providing subsidized student health insurance plan (SHIP) coverage to graduate students or face penalties. The guidance included temporary enforcement relief, and in October 2016, the departments issued an FAQ extending that relief indefinitely. The groups requested permanent relief from the February 2016 guidance so that institutions can continue providing subsidized SHIP coverage to graduate students without penalty.

Along with ACE, associations signing the comments include:

  • American College Health Association
  • Association of American Universities
  • Association of Public and Land-grant Universities
  • College and University Professional Association for Human Resources
  • Council of Graduate Schools
  • National Association of Independent Colleges and Universities

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