ACHA Submits Comments to Department of Health and Human Services on Proposed Rule That Designates Self-Funded Student Health Coverage as Minimum Essential Coverage


On February 1, 2013, the Centers for Medicare & Medicaid Services (CMS) posted a Notice of Proposed Rule Making [pdf] (CMS-9958-P) that, among other provisions, will designate self-funded student health coverage as minimum essential coverage under the Affordable Care Act (ACA). Within the notice, CMS requested comments on this action (see page 7361 of the Federal Register posting).

On behalf of the ACHA membership, ACHA President Jenny Haubenreiser has submitted comments [pdf] acknowledging the proposed inclusive action by the Department of Health and Human Services (HHS), and pledging ACHA’s continued commitment and vigilance in promoting high-quality coverage for the nation’s college students. The proposed action set forth in these draft regulations is entirely consistent with ACHA’s longstanding advocacy position regarding this issue as first conveyed in ACHA’s April 12, 2011 letter [pdf] commenting on the earlier proposed regulations (now final) regarding Student Health Insurance Coverage under the Public Health Service Act and the Affordable Care Act. ACHA is both appreciative and supportive of the HHS Secretary’s inclusive action with regard to self-funded student health coverage in this proposed rule.