Dear Sir or Madam:
Young Invincibles is a non-profit, non-partisan organization that works to amplify the voices of young Americans and expand economic opportunities for our generation. As one of the leading organizations focusing on young adults and heath care, we thank you for this opportunity to comment on minimum essential coverage.
If approved, the proposed rule, which counts self-funded student plans as minimum essential coverage with no requirements attached, will expose many students to gaps in health care coverage, the very gaps in coverage that the Affordable Care Act intended to solve. This proposal would compromise the health of young Americans. In states that have refused to move forward with Medicaid expansion, this leaves the most vulnerable young people without access to quality coverage. We urge you to take approaches other than the automatic exemption of all self-funded student plans from the terms of the ACA. Specifically, we ask that HHS:
- Reject the current proposal to allow self-funded student health care plans to qualify as minimum essential coverage under the ACA, and utilize an alternative form of exemption, which allows for the approval of plans that substantially comply with ACA protections.
- Require self-funded student health care plans to show that they mirror individual coverage in order to be approved as minimum essential coverage;
- Work with the Department of Treasury to ensure that students attending schools offering self-funded student health insurance are not barred from rejecting those plans and instead getting tax credits on the exchange.
Taking these steps will help ensure that students covered by their school’s self-funded plan receive protections comparable to those offered under other plans, and that students have access to other options that may have been quality and better value.
To read the full comment, click here.
Comments on Proposed Rule on Patient Protection and Affordable Care Act; Exchange Functions: Eligibility for Exemptions; Miscellaneous Minimum Essential Coverage Provisions [RIN 0938-AR68]
Dear Sir or Madam:
Young Invincibles is a non-profit, non-partisan organization that works to amplify the voices of young Americans and expand economic opportunities for our generation. As one of the leading organizations focusing on young adults and heath care, we thank you for this opportunity to comment on minimum essential coverage.
If approved, the proposed rule, which counts self-funded student plans as minimum essential coverage with no requirements attached, will expose many students to gaps in health care coverage, the very gaps in coverage that the Affordable Care Act intended to solve. This proposal would compromise the health of young Americans. In states that have refused to move forward with Medicaid expansion, this leaves the most vulnerable young people without access to quality coverage. We urge you to take approaches other than the automatic exemption of all self-funded student plans from the terms of the ACA. Specifically, we ask that HHS:
Taking these steps will help ensure that students covered by their school’s self-funded plan receive protections comparable to those offered under other plans, and that students have access to other options that may have been quality and better value.
To read the full comment, click here.