114.6 CMR 3.00 Student Health Program

1. 114.6 CMR 3.00Student Health Program Adopted regulation changes for June 1, 2009 effective date

2. Adopted Changes to 114.6 CMR 3.00 • Qualifying Event • Reporting and Documentation • Communication with Students about Coverage and Waiver Process • Technical Changes • Adopted changes that differ from those proposed in March 2009 are highlighted with bold italics.

3. Qualifying Event Changes The adopted regulatory changes requires schools to: • Consider the termination from another health benefit plan, including MassHealth and Commonwealth Care, a qualifying event. • Prorate premiums, based on the month of enrollment in the Student Health Program, for students whose coverage under another health benefit plan has been terminated.

4. Reporting and Documentation Changes Changes in the adopted regulation include: • Revised reporting requirements calling for schools to submit additional health plan benefit description information, including: • Description of health plan benefits in a format specified by the Division, • Plan Evidence of Coverage (EOC), and • Plan marketing materials. • New data submission requirements calling for schools to submit health plan performance metrics to the Division, which include (but is not limited to): • Rate of claim denials, • Number of grievances, • Plan administrative costs, • Plan medical costs, and • Medical loss ratio. • Reducing the number of required filings from three filings to two filings a year. • November 1 filing will collect enrollment information for the current school year and plan performance metrics for the previous school year. • May 1 filing (formerly March 1) will collect updated enrollment information for the current school year and Student Health Program benefit information. • Schools that do not have an EOC that has been approved by the Division of Insurance (DOI) by the specified deadline must submit their EOC within 7 days of receiving DOI approval. • Removing the requirement for schools to obtain documentation of comparable coverage from students as part of the waiver process. • Requiring schools to retain a copy of the Evidence of Coverage for record-keeping purposes.

5. Communication with Students about Coverage and Waiver Process Changes The adopted regulation requires schools to: • Post their Student Health Program’s Evidence of Coverage (EOC) and related health benefit information on their website. • Notify students of the website’s availability at the same time registration materials become available, but no less than 30 days in advance of the registration deadline. • Schools that do not have an EOC that has been approved by the Division of Insurance (DOI) by the specified deadline must post their EOC within 7 days of receiving DOI approval. • Designate a staff member as the student resource for their school’s Student Health Program. • Clearly communicate their waiver process and the timelines associated with the waiver process to their students.

6. Technical Changes The adopted regulation also changes: • The program name from “Qualifying Student Health Insurance Program” to “Student Health Program.” • The definition for “Institution of Higher Education” to “School.” • References to the “Uncompensated Care Trust Fund” and its accompanying regulatory citations to the “Health Safety Net” and its regulatory citations. • Some formatting issues to ensure that formatting and spacing is consistent throughout the regulation.