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Understanding Student Health Insurance Plans in Higher Education

This overview discusses Student Health Insurance Plans (SHIPs) in relation to the ACA, employer mandates, and student employment. Delve into the requirements, coverage, subsidies, and potential impacts on graduate students. Stay informed on essential health benefits and regulatory compliance.

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Understanding Student Health Insurance Plans in Higher Education

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  1. Selected ACA and Higher Education Issues Council on Government Relations Steven M. Bloom October 22, 2015

  2. Overview • Student Health Insurance Plans (SHIPs) • ACA, Employer Mandate, and Student Employment • ACA and Graduate Student SHIP Coverage

  3. Student Health Insurance Plans (SHIPs) – Overview • Schools are not required to provide SHIPs under the ACA because students are not employees. • Under HHS regs, SHIPs defined as a type of Individual health insurance coverage, subject to ACA’s individual insurance reforms. • Not sold on individual market. Other than self-funded schools, plans provided by a school through a health insurance company. • Onlyavailable to enrolled students and their dependents, with schools permitted to define eligible student/dependents.

  4. SHIPs Overview - Continued • SHIPs will be considered minimum essential coverage (MEC) for individual mandate if they meet regulatory requirements: • No pre-existing conditions discrimination or dropping coverage if a student (or dependent) gets sick. • No life-time and annual limits on essential health benefits. • SHIPs exempt from guaranteed renewability and availability requirements. • Must provide specified essential health benefits, preventative care, broad prescription drug coverage, and in general, contraceptive coverage.

  5. ACA, Employer Mandate, and Student Employment • Employer Mandate • Larger employees (100 +) – 70% employees by Jan. 1, 2015, 95% by Jan. 1, 2016 • Smaller employees (50-99) - Jan. 1, 2016 • Definition of Full Time Employee – 30 or more hours • Adjuncts • Treasury Formula = 1 x 1.25 e.g. 9 credits • Student Workers • Work Study and FLSA Activity Based Approach • Undergrads and Graduate Students • Hours tracking and potential alternative proposals

  6. ACA and Graduate Student SHIP Subsidies • Graduate Student SHIP subsidies • Often provided as part of graduate package or related to activity e.g. teaching, research, graduate assistant • IRS Notice 2013 – To prevent end run around employer mandate. • 2015 – Became aware could interfere with Grad Student SHIP subsidies. • Discussions with regulators • Issues: • Fringe benefit or scholarship/grant • Form of taxable income?

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