Do student health care plans have to cover preventive care at no charge?
Yes (with the exception of some self-insured student health plans). Student health insurance plans must include preventive care and cannot impose any cost-sharing for certain recommended preventive services, as is the case for all non-grandfathered health plans. From the perspective of the enrollee, student health insurance plans are fully compliant with the ACA, which includes covering the essential health benefits. And covering certain types of preventive care at no charge is one of the essential health benefits.
Do student health plans have to cover contraceptives?
In most cases, yes. However, if the school has religious or moral objections to contraception, it can offer a student health plan that doesn’t include coverage for contraceptives, and can opt out of the accommodation process that would allow women enrolled in the plan to obtain zero-cost contraception at no cost to the plan issuer. But the Biden administration has proposed a rule change in 2023 that would eliminate the moral objection pathway for an entity to obtain an objection, and also ensure that women enrolled in a plan with a religious objection exemption would still have access to zero-cost contraception.
Do student health plans have to cover vaccines?
Yes. Just like any other non-grandfathered ACA-compliant plan, student health plans must cover vaccines recommended by the CDC’s Advisory Committee on Immunization Practices, including vaccination for COVID-19. (Although health plans — including student health plans — are only required to fully cover the cost of COVID testing through the end of the COVID public health emergency period, which is expected to end in May 2023, they will continue to have to cover the cost of COVID vaccines even after the public health emergency period ends, just the way they have to cover the full cost of other routine vaccinations.)
In the Benefit and Payment Parameters for 2017, HHS clarified that student health plans do not have to fall within the narrow actuarial value parameters that apply to metal level plans in the rest of the individual market. And they also do not have to be combined with the carrier’s other individual market business in a single risk pool. These adjustments make it easier for health insurance carriers and universities to continue to offer student health insurance, but their impact from the students’ perspective is minimal. Students can rest assured that the coverage they’re buying through a university is fully compliant with the ACA, unless it’s one of the aforementioned self-insured student health plans, some of which have opted out of ACA compliance.
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