Federal Bulletin Finalized on Health Insurance Discontinuance and Renewal Notices
On July 17, 2014, ACHA submitted comments to the Center for Consumer Information & Insurance Oversight (CCIIO) addressing draft health insurance discontinuance and renewal notices under the Affordable Care Act (ACA) and the effect of these proposed notice requirements on institutions and their student health plans. Comments focused on the unique nature of student health insurance plans and sought additional flexibility for institutions and their student health plans as federal policymakers finalized the guidance bulletin.
On September 2, 2014, CCIIO released the resulting guidance. Flexibility regarding student health insurance coverage and notice requirements is addressed on page 8 of the bulletin. ACHA is pleased that policymakers have acknowledged the unique nature of student plans and specified notice provisions that are consistent with their special design and interrelationship between the student, the institution, and the insurance issuer.