ACHA submits comments to CMS on the proposed rule for the application of the ACA to the Benefit and Payment Parameters for 2017


On December 2, 2015, the Centers for Medicare and Medicaid Services (CMS) released a proposed rule, for the application of the Patient Protection and Affordable Care Act to the Benefit and Payment Parameters for 2017 (CMS-9937-P). On behalf of the ACHA membership, ACHA President Jake Baggott, MLS, 1SG (USAR Retired), FACHA, and ACHA Executive Director Matt Granato, LLM, MBA, with the assistance of the Student Health Insurance/Benefits Plans Coalition, submitted comments addressing the effect of the proposed rules on institutions and their student health plans. ACHA is pleased that the proposed rule would permit insurance issuers to establish separate risk pools for student health insurance coverage at individual institutions of higher education, or multiple risk pools within a single institution. The letter also addressed a concern that the timing of rate approval will cause a longer process in the renewal of student health insurance coverage (SHIC) plans. In addition, ACHA fully supports the proposed rule to require student health insurance plans to provide only a minimum actuarial value (AV) of at least 60%, thus exempting them from the AV requirements established in section 1302(d) of the ACA, (wherein the actuarial value de minimis variation limits forced some institutions to downgrade their plan to fall within the next AV range.) ACHA will continue to monitor the development of these notice requirements as the rule is finalized.