NASFAA Urges Action on Student Health Insurance Coverage Regulations

NASFAA joined the American Council on Education (ACE) and six other associations to urge the Department of Health and Human Services (HHS) to immediately issue the final version of student health insurance coverage regulations or delayed the regulations until the 2013-14 academic year.

In a letter to HHS Secretary Kathleen Sebelius, the associations point out that schools that provide health insurance coverage to their students are already in negotiations over the cost and coverage of their plans for 2012-13. In addition, schools that include health insurance fees in their costs of attendance need information about the insurance fee for financial aid packaging purposes.

"Schools can, of course, estimate the amount required for health insurance, but doing so is likely to hurt the student," the letter states. "If schools find that they have underestimated the cost after committing all of their aid, students will be forced to find the additional funds from other sources. Schools that overestimate would have to revise aid packages, and possibly students would be required to repay the additional funds they received. From the perspective of both schools and students, neither result is desirable."

Proposed rules for Student Health Insurance Coverage (SHIC) were published by HHS in the Federal Register on February 11, 2011, with comments due by April 12, 2011. Unlike the Department of Education, HHS is not subject to a master calendar that requires publication of rules by a certain date in order to affect an upcoming award year. As a result, late-arriving final rules can disrupt the aid cycle by changing one of the costs that factor into packaging at some schools.