CAA Journal

Navigating Uncertainty

“The goal of leadership is not to eradicate uncertainty, but rather to navigate it.”

– Andy Stanley

Given the uncertainty surrounding the Affordable Care Act and other regulatory issues, many secondary schools are concerned about how they will continue to offer health insurance coverage for their International and Domestic student populations.   This uncertainty comes at a critical time as schools share re-enrollment contracts with their families for the upcoming 2017/2018 academic year.  Hopefully most schools are aware of these challenges through their broker and are planning accordingly.

Over the past several years, a series of regulations and rulings have made designing coverage for secondary school students a significant challenge.  In that context, some Insurance companies have decided to exit the market reducing the number of viable options.   Most recently (on 10/31/16), Health & Human Services issued a ruling that restricted short term limited duration policies to 3 months in length thereby removing one of the tools that many companies had used to provide coverage for secondary school students (in particular Domestic students).

As a broker solely dedicated to the student health insurance market for secondary schools, we remain fully committed to providing solutions that comply with existing law/regulations.  Below please find excerpts from a brief summary we recently shared with the schools we serve.

  1. We are still limited to an end date of 12/31/17 for Domestic students. With that said, we are staying on top of developments and pursuing separate solutions. Once again, the coverage you offer through us for your International students remains unaffected (12 months, 10 months and short term coverage is available).
  2. Legislative update
    1. American Health Care Act (AHCA) withdrawn – On Friday, 3/24/17, House Leadership withdrew their “repeal and replace” bill given the forecast that it would not have enough votes to pass.  The Administration and House Leadership have both said that they are moving on to other priorities (tax reform, etc.).  With that said, given the pressure that exists, another attempt may be made earlier than currently anticipated.  We will stay on top of all those developments and keep you posted.
  3. Suggested approaches – As a reminder, here is a summary of the most common approaches schools are taking given the current limitation of only having Domestic coverage available through 12/31/17.
    1. Separate – Student Insurance as a separate communication – If student insurance is part of a school’s enrollment process (contract, communication or web posting), most are electing to separate it out for the 17/18 year.  This reflects the fact that the enrollment contract covers the full Academic Year whereas the student insurance plan for Domestic students currently only goes through 12/31/17.  Further, this enables the school to differentiate between International and Domestic family communication.
    2. Postpone – Many schools are electing to delay their student insurance communication until later in the Spring (April/May). This provides additional time to think through the issue and provides a window of time for a potential solution.   To be clear, while we are hopeful, and working diligently, for a solution, it is impossible to predict specific timing.
    3. Not offer – Many schools are considering not offering the plan to their Domestic population while guiding them to ensure they have secured acceptable coverage on their own.  Please note that your Domestic families may not be able to secure coverage through the Exchange (open enrollment ended on 1/31/17).  In order to be eligible to enroll after 1/31/17, the purchaser must have a “qualifying event”.  The loss of the plan you offered does not typically meet the definition of a “qualifying event” since the plan was less than 12 months in length (and therefore does not meet the Affordable Care Act definition of previous qualifying coverage).
    4. Cover Medicaid students –  Even if they don’t offer the plan to their entire Domestic population, many schools will enroll their out of state Medicaid students through 12/31/17.  This provides protection for those students for the “fall term” and extends the window for a solution to be provided.

These are uncertain times.  As always, rest assured we are working to navigate that uncertainty and will do everything in our power to provide needed, comprehensive coverage within the context of the law.  We would encourage you to seek outside counsel on how this regulatory environment may impact the plans offered by your institution and, therefore, the families you serve.   If you have any questions, please feel free to contact our office.

Sincerely,

Ford

 

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