ACHA Submits Comments to Department of Health and Human Services on Proposed Rule Making for Health Insurance Market Rules and Rate Review

12/20/12.

On November 26, 2012, the Centers for Medicare & Medicaid Services (CMS) released a Notice of Proposed Rule Making [pdf] (CMS-9972-P) concerning health insurance market rules and rate review. Specifically, CMS requested comments on whether the final rule should allow issuers of college student health insurance to maintain a separate risk pool for SHIP coverage, and whether the final rule should provide any modifications with respect to the generally applicable individual market rating rules in connection with student health insurance coverage.

On behalf of the ACHA membership, ACHA President Jenny Haubenreiser has submitted comments [pdf] urging the Department to specify that SHIPs be exempted from inclusion in an issuer’s individual market single risk pool in the final rule. The letter expressed the concern of ACHA leadership that doing otherwise would render premium pricing cost prohibitive and essentially diminish institutions’ ability to offer affordable comprehensive coverage tailored to the needs of college students.