ACHA Health Care Reform Regulatory Update — February 9, 2011:

02/09/11. ACHA is pleased to see the announcement of proposed federal regulations implementing provisions of the Patient Protection and Affordable Care Act (“ACA”) as they relate to the continued operation of college student health insurance plans. ACHA thanks the Administration for the opportunity to provide input during the process, and is appreciative of the thoughtful and deliberate work undertaken by federal officials to craft regulations that will guide colleges and universities regarding their student health insurance plans.

While ACHA input was provided, we fully understand that policymakers considered multiple perspectives. We are pleased that the Proposed Rule recognizes the important role that higher education institutions should play in the future in providing insurance coverage for many college students. We are pleased that the Proposed Rule maintains a specific category of “student health insurance coverage” as a type of individual health insurance coverage with a specific set of guidelines for satisfying ACA requirements that will enable colleges and universities to continue offering high quality student health plans in full compliance with ACA. We also recognize that questions about self-funded student health plans remain, as these plans were excluded in the proposed regulations, and are left to state regulation.

The announced Notice of Proposed Rulemaking includes a public comment period. In the weeks ahead, ACHA will be examining these proposed regulations in detail and provide comments as appropriate regarding their impact on student health insurance plans. We encourage those with comments to provide them to ACHA no later than March 11, 2011 via the following email address: ACA_SHP_Regs@acha.org. We welcome the input of all ACHA members.

ACHA believes that these regulations will improve the insurance coverage formerly provided by some lower quality student health insurance plans. We are confident that implementing the ACA via this regulatory guidance will help assure quality, affordable health care and health promotion for college and university students into the future.