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45 CFR 147.145 - Student health insurance coverage.

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  • 45 CFR 147.145 - Student health insurance coverage.

    This page provide an excellent summary for regulation of student health insurance coverage provided by colleges and universities: https://www.law.cornell.edu/cfr/text/45/147.145,

    I have two comments. First, I think the definition for Student Administrative Health Fees should be augmented with this provision on page 16456 of CMS-9981-F: “Student administrative health fees are those that are charged to all students enrolled at a college or university, regardless of whether a student enrolls in student health coverage or utilizes any services offered by the clinic, which gives all students access to a student health clinic’s services and supports a number of services and activities that foster a healthier campus community."

    Second, the review of student health insurance coverage would be more complete if it made reference to self-funding of student health benefit plans. The guidance from Centers for Medicare and Medicaid Services for self-funded student health plans obtaining recognition as having Minimum Essential Coverage was issued on October 31, 2013: https://www.google.com/url?sa=t&rct=...qpdI2wz-nTi--p.

    Again, great job in providing this summary

    Stephen Beckley
    Hodgkins Beckley Consulting
    www.hbc-slba.com
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