The Department of Health and Human Services (HHS) yesterday released the text of proposed regulations that would ensure college and university health plans offer students the consumer protections created by the Affordable Care Act (ACA), the health care reform legislation signed into law last year.
The new rules are in part a response to a request from ACE, the American College Health Association and several other organizations for guidance to help colleges and universities navigate the changing landscape for health care and health insurance since the enactment of the ACA.
The regulations, which would go into effect Jan. 1, 2012, would define college plans as “individual health insurance coverage” with the same protections the new law gives to other individual plans, including no lifetime limits on coverage, no arbitrary rescissions of coverage and no exclusions for pre-existing conditions. These provisions would not apply to plans negotiated before 2012, which would include all plans active during the 2011–12 academic year.
“The regulations helpfully provide colleges and universities with reasonable time to transition their student health plans to come into compliance with the ACA, as well as ensure that their plans are only available to students and their dependents and are priced based only on the campus student population,” said Steven Bloom, director of government relations for ACE. “We’re pleased that HHS listened to the unique concerns of higher education and the needs of students, and that they responded to our request for guidance so campuses can continue to offer affordable, high-quality student health plans.”
However, Bloom expressed concern that despite requests, the proposed regulations do not address how institutions that self-insure their student health plans should handle their plans under ACA. ACE will be communicating this concern, and perhaps others, to HHS in the coming weeks as the rules are finalized.
The regulations will be published in the Feb. 11 Federal Register. HHS will be accepting comments for 60 days, through April 12.
HHS Fact Sheet on the proposed rules
Reform for Student Health Plans
Inside Higher Ed (Feb. 10, 2011)
Colleges' Student Health Plans Would Offer More Protections Under Proposed Rules
The Chronicle on Higher Education (Feb. 10, 2011)
College Plans Required to Comply With Health-Care Law
The Wall Street Journal (Feb. 9, 2011)