Student Health Insurance Program Regulation in Massachusetts

What regulations exist for Student Health Insurance in Massachusetts?

The Commonwealth of Massachusetts has set a specific level of benefits for health insurance plans that are sponsored by a college or university. Since 1989, Massachusetts has required that all students considered full-time or 75% of full-time while enrolled in a degree-granting program at an institution of higher learning in Massachusetts participate in a compliant, school-sponsored health insurance plan or in a health insurance plan with comparable coverage. This requirement exists regardless of the student’s state of residency.

You may see the term ‘QSHP’ as it relates to the regulation of Student Health Insurance Programs offered by colleges and universities in the Commonwealth of Massachusetts.  In 2009, amendments to regulations re-named QSHP to ‘Student Health Insurance Program Regulation’ or SHP.

Why was Student Health Insurance Program Regulation developed in Massachusetts?

Regulation was established to promote students’ access to quality and comprehensive health insurance while attending school in Massachusetts. When originally established, many insurance plans did not provide coverage for dependents who were full-time students over the age of 19 and the Regulation allowed students to have access to an affordable health insurance alternative. Additionally, such Regulation allows international students access to the same coverage of health benefits as domestic students. Requiring participation in a compliant, school-sponsored plan or comparable alternative plan also ensures that students will have health services available in close proximity to their school.

Do part-time students have to enroll or complete a waiver?

Student status depends on the number of credits in which the student is enrolled. Students required to enroll (or prove comparable insurance) are defined as a student participating in at least 75% of the full-time curriculum. The number of quarterly, trimester, or semester credits that represents this 75% of full-time curriculum varies from school to school. Students should confirm how their school determines credit requirements before assuming the health insurance requirement is not applicable to them.

Are students registered for a full-time load of online courses subject to the SHP requirement?

No. Currently, any student registered in an online program in Massachusetts, regardless of that student’s state of residency, is not required to participate in the school-sponsored plan or show proof of an alternate insurance plan of comparable coverage.

If a student already has health insurance, does he or she have to be enrolled in the school insurance?

Students who are covered under a health insurance plan of comparable coverage can waive the school’s plan. In order to waive, students must submit a waiver form annually at the beginning of each academic year to the school and certify that they are enrolled in another comparable plan. The following information is required for proof of comparable coverage: name of the insurance company, policy number or member identification number, name of the subscriber or primary enrollee and the relationship of that person to the student, and a statement that their current insurance is comparable to the coverage required under Massachusetts regulations. The specific waiver process is dictated by the school, and most schools choose to use an online system for students to submit waivers.  This waiver process must be done on an annual basis at the beginning of each academic year (or beginning of the spring semester for those students who begin their academic year in the spring), and many schools stipulate that waiver information may be subject to audit.

If a student has insurance through their parents or an employer plan; how do they know if that is comparable coverage?

An alternate plan must provide comparable coverage to that offered through the college or university.  Comparable coverage includes, but it not limited to, the following services to a student throughout the school year:

1. Reasonably comprehensive coverage of health services, including preventive and primary care, emergency services, surgical services, hospitalization benefits, ambulatory patient services, and mental health services; and
2. Services must be reasonably accessible and in close proximity to the school location.
3. Access to providers in the geographic area of the college or university.
   It is important to note that a health plan that only has a closed network of providers (i.e., no national network) and/or only provides access for emergency services when a student is out-of-area is not considered comparable coverage.
   
4. The insurance company should be one based in the United States.

Why should parents find it important to look at their insurance coverage?

It is the responsibility of the student and/or parent(s) to determine if their insurance coverage is comparable. These minimum health benefit standards for students were established by the Massachusetts Division of Health Care Finance and Policy (now the Center for Health Information and Analysis). This Division, in cooperation with the institutions of higher learning in Massachusetts is responsible for administering compliance with the student health insurance requirement. An appropriate level of insurance coverage is not only required as a condition of enrollment, but is necessary to ensure that your child has access to health care while away at school.

What if a student doesn’t have health insurance or their coverage is not comparable, how do they enroll in school insurance plan?

Schools will automatically enroll students in the school sponsored insurance plan and include the cost of the insurance in the tuition bill, unless the student shows proof of comparable coverage in an alternate health plan via the school’s designated waiver system.

What is the percentage of students who enroll in the school sponsored plan?

At Massachusetts institutions, the number of students enrolled in the school sponsored plan is 30-35%.

Do students have to fill out a waiver form annually?

Yes. Recognizing that health insurance coverage may change, schools must require students with comparable coverage to complete a waiver form at least once a year, as part of the school’s usual registration process.

Can international students waive out of the school insurance?

In general, international students can waive out of the school insurance if they are enrolled in a comparable insurance plan provided by a U.S.-based insurance company.  However, at their discretion, individual schools can require that all international students be enrolled in the school-sponsored Insurance Plan, or they can allow international students to waive.

In the event waivers are permitted, schools may not grant a waiver request if the student has coverage issued by an insurance carrier who is not based in the U.S. or if the plan is not considered comparable coverage. Insurance coverage through a carrier outside the U.S. or from foreign National Health Service programs can be waived only if the student is studying in a foreign country and the foreign insurance plan provides coverage in that location.

Can a student waive the Student Health Insurance Program (SHP) with any of the Massachusetts (MA) state subsidized insurance plans such as Health Safety Net or any other subsidized plan through The Commonwealth Connector?

Students who are eligible for a school-sponsored Student Health Insurance Plan through their college or university are not eligible to participate in any of the Massachusetts- subsidized Commonwealth Care programs. These programs cannot be used to waive the student health insurance plan. Students are eligible to purchase one of  the insurance plans offered through Commonwealth Choice (unsubsidized), but these plans should be reviewed carefully as they may have very high deductibles and often times limited benefits and may not provide benefits comparable to a school-sponsored insurance plan.

If a student is currently enrolled in MassHealth; can this plan be used to waive the school insurance plan?

MassHealth covers students who are dependents under a family plan until the age of 19. If you or your student are 19 or older you can still be enrolled in MassHealth, but only if you meet specific criteria. Contact MassHealth to determine whether or not you can be covered over the age of 19. If eligible, MassHealth can be used to waive the school-sponsored insurance plan.

Federal Health Care Reform

How does Health Care Reform affect a student’s ability to waive out of the school insurance plan?

If the student is under the age of 26, students MAY be eligible to enroll as a dependent under the employer health insurance plan held by their parent(s). However, before doing so, students/parents should fully compare the employer plan against the school-sponsored plan to determine which plan’s rates, benefits and coverage are most appropriate.

In addition to the items mentioned in the waiver question above, keep in mind that Student Insurance Plans are generally less expensive than individual plans with similar benefits. In fact, total out-of-pocket costs (including premium and deductibles) may be significantly LESS with the school’s sponsored plan, especially if the plan carried by the student’s parents or one offered by an employer is considered a ‘high deductible’ plan or only offers coverage in a limited service area. In addition, please note that most retiree plans are exempt from allowing students to continue on the Plan through age 26.

What changes did Health Care Reform make to school-sponsored insurance plans?

For plans that renew on or after July 1^st of each year, the Annual Plan Maximum Levels can be no less than:

·     2012-2013: $100,000 Per Policy Year

·     2013-2014: $500,000 Per Policy Year

·     2014 and beyond: No Annual or Lifetime Maximum

Additionally, for plans that renewed on or after July 1, 2012, the following provisions apply for a Student Health Insurance Plan to be considered PPACA-compliant:

·     No internal annual dollar limits can be applied to ‘Essential Benefits’ (number of visits limits can still apply).

·     Preventive care is covered at 100% without cost-sharing at in-network providers. For more information on Preventive care coverage (including women’s health coverage), visit http://www.healthcare.gov/law/features/rights/preventive-care/index.html

·     Student Plans with dependent coverage must now cover dependents up to age 26

What insurance categories are considered ‘Essential Benefits’?

·     Ambulatory Patient Services

·     Emergency Services

·     Hospitalization

·     Maternity & Newborn Care

·     Mental Health / Substance Abuse  Disorder Services

·     Rehabilitative Services

·     Durable Medical Equipment / Devices

·     Prescription Drugs

·     Diagnostic Tests

·     Wellness / Preventive Care

Please note that specific definitions and limitations under each Essential Benefits category may vary by each insurance company.

Who is CHIA/ the Division of Health Care Finance & Policy?

On November 5, 2012, a phase of Massachusetts health care reform (Chapter 224 of the Acts of 2012) went into effect, dissolving the Division of Health Care Finance and Policy (DHCFP) and a new, independent state agency—the Center for Health Information and Analysis (CHIA)—has assumed many of DHCFP’s responsibilities, including QSHP/SHP. CHIA has also taken on new roles in support of its mission to examine health care cost and quality information and provide objective data and analysis to assist in the formulation of health care policy.

Additional Resources

Gallagher Koster (AICUM partner Student Health Insurance Agency):
http://www.gallagherkoster.com

Massachusetts Student Health Insurance Regulations:  
http://www.mass.gov/chia/consumer/basic-needs/student-health-insurance.html

The Massachusetts Health Connector:
www.mass.gov/connector

Massachusetts Division of Insurance (DOI):
http://www.mass.gov/doi

U.S Department of Health & Human Services HealthCare.Gov:

http://www.healthcare.gov/index.html

The Kaiser Family Foundation Healthcare Reform Information:

http://healthreform.kff.org/