ACHA Submits Comments to State Department Final Regulation on the Exchange Visitor Program


On October 6, 2014, the Department of State released a final rule on the Exchange Visitor Program [pdf]. Within that document, health insurance requirements for exchange visitors are addressed on page 60304, and set forth as regulation on page 60316
(§ 62.14 Insurance). Publication of the final rule also included solicitation of comments.

On behalf of the ACHA membership, ACHA President Sarah Van Orman, MD, MMM, FACHA, with the assistance of the Student Health Insurance/Benefits Plans Coalition , submitted comments expressing concern regarding the requirements. Specifically, ACHA voiced concern that the health insurance coverage requirements set forth in the final rule were not more robust and appear inconsistent with the federal government’s intent under the already enacted Affordable Care Act (ACA) legislation and its implementing regulations aimed at improving coverage and consumer protection. ACHA points out that inclusion of dollar limits (caps) on coverage, permissible waiting periods for pre-existing condition coverage, non-industry standard deductibles, and the absence of both a limit on out-of-pocket expenses and carrier accountability are problematic and should be addressed to assure high-quality and affordable coverage for exchange students comparable to the reforms that enhanced student health insurance quality under the ACA.

ACHA stands ready and willing to assist the State Department in the furtherance of high-quality health insurance coverage for exchange visitors.