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Business and Policy Areas
Business and Policy Areas

Student Health Insurance To Be Rated Separately

March 7, 2013

Final health insurance market rules published by the Department of Health and Human Services (HHS) on February 27 will not subject student health insurance coverage to the single-risk pool requirement under the Affordable Care Act (ACA). Instead, the premium rate for such plans may be based on a school-specific group community rate, if the issuer offers the coverage without rating for age or tobacco use.

HHS had suggested that student health insurance be included in the general individual market risk pool in proposed rules published on November 26. NACUBO joined the American Council on Education and several other associations in comments objecting to combining student health plans with all other individual coverage in each state to set premium levels. (Student health plans are not considered group plans under the ACA because they are not offered by an employer.) The associations were concerned that doing so would drive up costs for students who, as a group, tend to be younger and healthier than the general population.
HHS notes, however, that this treatment of student health insurance is a transitional policy. The agency promises to monitor student health insurance during the 2014 implementation and may revisit the policy in the future.

In addition, the final rules exempt student health coverage from the guaranteed availability and renewability provisions of the ACA, allowing them to restrict coverage to students and their dependents. Further, such plans will not be subject to the standard open enrollment periods that will apply to other individual plans. Issuers will be able to work with the college or university sponsor to determine the appropriate schedules. 


Anne Gross
Vice President, Regulatory Affairs