ACHA Submits Comments to Department of Health and Human Services on Proposed Rule Making for Affordable Health Insurance Exchanges

09/30/11. On July 15, 2011, the US Department of Health and Human Services (HHS) proposed a framework [pdf] to help States build Affordable Insurance Exchanges. The proposed rule has been open for public comment and on behalf of the ACHA membership, ACHA President Anita Barkin has submitted comments [pdf] addressing the absence of information on the interaction of student health insurance plans with the proposed state health insurance exchanges. The underlying concern among the ACHA leadership remains the welfare of the college student in the individual insurance market. To that end, ACHA hopes to avoid disenfranchising students and their health care coverage needs by encouraging the Department to include provisions in the regulations that will:

  • Enable student health insurance plans to compete on a level playing field with other individual coverage options;
  • Provide lower income students who are eligible for the premium subsidy with a mechanism for access to the tax credit;
  • Ensure that student health insurance plans would not be subject to disproportionate assessments and user fees if they participate in the exchanges;
  • Accommodate the unique residency issues for students studying out of state with regard to their eligibility to participate in a state-based exchange; and,
  • Accommodate the unique enrollment periods for student health insurance plans.

We are hopeful that the final regulations incorporate ACHA’s input and that, college students will be able to take advantage of increasing options for comprehensive and cost-effective student health insurance plans in the future.