As implementation of the Affordable Care Act moves forward, Massachusetts policymakers continue to update state laws and regulations. Recently, the Health Connector released proposed regulatory changes to the Massachusetts Student Health Insurance Program (SHIP) (pdf).
Since the 1988 Dukakis universal coverage law, students attending Massachusetts colleges and universities have been required to have health insurance. The state has required all colleges and university to offer a SHIP, and gives schools the discretion as to whether to require students to take the SHIP or keep or enroll in other comparable coverage.
Many SHIPs had traditionally offered less than comprehensive coverage and the insurance carriers offering these plans made substantial profits off of the students. Many of the student plans had very low “medical loss ratios,” meaning they spent less on medical care and more on administrative costs). In recent years, the Health Connector collaborated with the Department of Higher Education and other agencies to improve benefits in SHIPs at state and community colleges.
ACA implementation offers further opportunities to improve SHIPs and enable students greater access to health coverage, particularly those from low-income families. For instance, today, low-income Massachusetts residents who are college students lose their MassHealth coverage upon turning 19. With the ACA Medicaid expansion, these students will be able to continue or become eligible for MassHealth as long as they meet the income thresholds, no matter their age.
More importantly, today college students are also locked out of Commonwealth Care coverage due to access to SHIPs. Starting in 2014, with the ACA, low-income college students not eligible for MassHealth may be able to get help paying for health insurance through the Health Connector.
The Health Connector made further changes to the state’s SHIP regulations to both comply with the ACA and further strengthen and streamline the SHIP. We appreciate that the Health Connector took many of HCFA’s suggestions into account when developing these rules.
The proposed regulations include many improvements that will help low-income students with the cost of SHIP coverage, such as requiring schools to:
- Give students the opportunity to enroll in partial year coverage, which may be prorated by term, which can help with the affordability of SHIP coverage;
- Offer students a prorated premium refund to any student who paid to enroll in a SHIP for entire school year but who is not a student at the beginning of a term during the school year; and requiring that schools; and
- Accept MassHealth or subsidized health insurance coverage through the Health Connector as comparable coverage.
In addition, the proposed regulations strengthen coverage by requiring that all SHIPs – both fully-insured and self-funded – comply with ACA insurance market reforms and consumer protections, including covering Essential Health Benefits (EHBs), eliminating annual and lifetime limits, and not charging cost-sharing for preventive services. The regulations also require SHIPs to comply with cost-sharing provisions of the state’s Minimum Creditable Coverage standards.
The SHIP regulations are open for public comment. A public hearing is scheduled for Tuesday, November 19th at 9:00 at Asbhurton Café (in the basement of 1 Ashburton Place). Written comments are due by November 15th to firstname.lastname@example.org.
We appreciate the Health Connector’s efforts to improve health insurance coverage for Massachusetts college students and look forward to providing more feedback during the public comment period.