NAICU Washington Update

HHS Announces Proposed Regulations for Student Health Plans

February 11, 2011

The U.S. Department of Health and Human Services has announced proposed regulations for student health plans. The proposals are extensive, and exact implications may require additional conversations with the White House and HHS officials.

An early read indicates that the regulations do provide additional guidance on classifications of types of student health plans, and how President Obama's new health law might affect them.  However, the effect on self-regulated student health insurance plans is less clear.  The higher education associations and institutions that have been working on student health issues over the past two years will be analyzing the regulations in more detail before deciding on the process and context for community comments.

Student health insurance advocate groups are applauding language that they see as requiring better quality plans.  Still, we anticipate many colleges and universities will be relatively unaffected if the regulations do go into effect, given that the language parallels current and future law requirements.  Plans not in compliance with current or upcoming changes in the law, though, may need to make modifications if the regulations are adopted.

The text of the proposed rule, released February 9, is available on line.  A fact sheet on the rule also is available.  Comments must be received by April 8, the end of the 60-day comment period.  Instructions for submitting comments are included in the notice.

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