ACHA Submits Comments to Department of Health and Human Services on Proposed Regulations for Student Health Insurance Coverage

04/12/11. On February 11, 2011, the U.S. Department of Health and Human Services (HHS) released proposed federal regulations [pdf] that would implement provisions of the Affordable Care Act (“ACA”) and the Public Health Service (PHS) Act as they relate to the continued operation of college student health insurance in the newly mandated health insurance marketplace. Since then, this notice of proposed rulemaking has been open for public comment through April 12, 2011.

ACHA encouraged interested members to provide email comments to the association via a special mailbox which was open for input through March 11, 2011. Those comments were reviewed and considered by ACHA’s leadership, with the aid of the ACHA Student Health Insurance/Benefits Plans Coalition, and the association developed its organizational comments regarding the proposed HHS regulations. While we acknowledge the broad constituency of ACHA’s membership, we have been steadfastly committed, throughout the advocacy process, to preserving comprehensive student health insurance plans that conform to ACHA’s guidelines document Standards for Student Health Insurance/Benefits Programs . We have consistently supported the continuation of such plans, and continue to encourage improvement in the insurance coverage of plans that do not currently meet these standards. To the extent that these proposed regulations help accomplish this, we have submitted constructive comment [pdf] to HHS for consideration in final rulemaking.

We are hopeful that the final regulations incorporate ACHA’s input and that in the end, a broader number of college students will benefit from more comprehensive coverage provided by college student health insurance plans.