health

The Administration last week issued favorable guidance with respect to student health coverage that will result in little disruption, if any, to this business until at least the 2012-2013 academic year. This guidance was announced in a Notice of Proposed Rule Making (rather than as an interim final regulation), which fortunately means that the rule is not effective immediately as has been the case with most regulations relating to PPACA reforms. The proposed student health rule would create a special class of individual coverage for student health pursuant to a set of factors, e.g., written contract between school and insurer, coverage only for students and dependents, health status may not be used as a condition of eligibility. 

 As Aetna has advocated, the impact would be delayed, as the rule (whenever finalized) would not be effective until policy years beginning on or after January 2012. Until then, student health is not subject to PPACA reforms.  And, when effective, student health would be excepted from the current guaranteed issue and renewability provisions of PPACA.  While it will be unclear for a while whether and how student health will be subject to the medical loss ratio (MLR) provisions of PPACA, we are encouraged by the fact that the proposed rule invites comments on whether student health should receive some sort of special accommodation (akin to the special rule for limited benefit plans) with respect to MLR, owing to the unique characteristics of the student health market.

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