Issued by: Centers for Medicare & Medicaid Services (CMS)

Issue Date: September 18, 2014

Program Area: Reinsurance-Contributions (RIC)

Question: Are student health plans required to make reinsurance contributions and are they eligible for the reinsurance payments?

Answer: Applicable to All Reinsurance Contributions Benefit Years: As stated in the U.S. Department of Health and Human Services (HHS) Notice of Benefit and Payment Parameters for 2015 Final Rule (79 FR 13779), in accordance with the policy established in the HHS Notice of Benefit and Payment Parameters for 2014 Final Rule (78 FR 15466), student health plans are not eligible to receive reinsurance payments. Under 147.145(b)(3), student health plans are not subject to the single risk pool requirement of section 1312(c) of the Affordable Care Act (ACA) and 156.80. Under 153.234, a reinsurance-eligible plan's covered claims costs for an enrollee incurred prior to the application of the following provisions do not count towards either the uniform reinsurance payment parameters or the State supplemental reinsurance payment parameters: 147.102 (fair premiums); 147.104 (guaranteed availability); 147.106 (guaranteed renewability); 156.80 (single risk pool); and subpart B of part 156 (essential health benefits). However, a student health plan would be considered part of a Contributing Entity's "commercial book of business" and, to the extent that the plan provides major medical coverage, as defined in 153.20, a Contributing Entity must make reinsurance contributions on behalf of their enrollees, absent another exception in 153.400.

HHS is committed to making its websites and documents accessible to the widest possible audience, including individuals with disabilities. We are in the process of retroactively making some documents accessible. If you need assistance accessing an accessible version of this document, please reach out to the guidance@hhs.gov.

DISCLAIMER: The contents of this database lack the force and effect of law, except as authorized by law (including Medicare Advantage Rate Announcements and Advance Notices) or as specifically incorporated into a contract. The Department may not cite, use, or rely on any guidance that is not posted on the guidance repository, except to establish historical facts.