ACHA Submits Comments to Draft Federal Bulletin on Health Insurance Discontinuance and Renewal Notices
On June 26, 2014, the Center for Consumer Information & Insurance Oversight released a bulletin containing draft standard notices [pdf] that health insurance issuers would use when discontinuing or renewing coverage under a product in the small group or individual market. Within the bulletin, on page 6, federal regulators included a section specific to Student Health Insurance Coverage and invited comments relative to the draft notice requirements and student health insurance.
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 [pdf] addressing 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, notwithstanding the fact that they are in the individual market, a consideration already acknowledged by their earlier exemption from the guaranteed renewability requirements of the Affordable Care Act (ACA).
ACHA will continue to monitor the development of these notice requirements as the bulletin is finalized.