Health Insurance Increases

BCEagle91 · November 7, 2012, 5:57pm

They just provide a form for you to fill out and you affirm that you have at least the minimum required coverage. The UMass Amherst site that I checked out said that they do conduct audits though.

What is your interpretation of the law though?

geeps20 · November 7, 2012, 5:59pm

From massresources.org: no mention of deductibles.

"You must enroll in your school’s SHP plan unless you have other health insurance with comparable coverage

Comparable coverage is health coverage that is at least as good as SHP.(student health plan) The health plan must offer the same type of benefits as SHP, but benefits do not have to be exactly the same.

In addition, the plan must allow you to get health services in the area where you attend school. "

BCEagle91 · November 7, 2012, 6:03pm

There are often websites with some points of the law but not all aspects of the law.

Northeastern University lists the deductible requirement but you have to have access to their portal to see it.

geeps20 · November 7, 2012, 6:06pm

BCEagle…just saw your link…hmmm…I take that as any SHP can’t have a ded over $250…BUT…I don’t think that means you can’t waive coverage if your family policy has a higher ded…Most plans have higher deds…so that wouldn’t make sense.

BCEagle91 · November 7, 2012, 6:12pm

My plan until last year had no deductible. This year it’s $200 for individuals and $600 for the family. The HSA has limits of $600 for individuals and $3,000 for families. My read of the law is that the $250 applies to individual limits so all of the plans where I work would satisfy the maximum annual deductible limit except for the HSA/HDHP.

BTW, on contacting a benefits administrator: we have 10K employees per benefits administrator. Unlikely that I’d get an appointment before enrollment is over.

BTW: thanks for actually reading it.

martina99 · November 7, 2012, 6:21pm

From a quick glance at the website, it says your plan does not have to be as good as the SHP. You can have a higher deductible, no prescription coverage etc. Your plan just has to meet minimum state standards.

As far as I’m concerned, we are fully compliant. We provided our insurance information and coverage and the waiver was approved.

No falsehoods involved.

geeps20 · November 7, 2012, 6:22pm

^ I disagree that any family plan with ded higher than $250 means you can’t waive the school coverage. $250 is limit for any HSA plan. The law talks about “comparable coverage” in terms of preventive care, ambulance, hospitalization ect. All family HD plans have these coverages, subject to deductible. With your own carrier, you are still benefiting from reduced rates even if you don’t meet the deductible.

From your link: No mention of HD plans below.

<ol>
<li>What types of health insurance plans are not considered comparable coverage?</li>
</ol>

Schools may not grant a waiver request if the student has coverage through the Health Safety Net, Commonwealth Care, or coverage issued by a foreign insurance carrier. Insurance through a carrier outside the U.S. or from foreign National Health Service programs is comparable only if the student enrolled in Massachusetts college is studying in a foreign country and the foreign insurance plan provides coverage in that location.

<ol>
<li>Is the alternate health insurance plan required to meet all the criteria of a SHP plan to be considered “comparable coverage”?</li>
</ol>

No. The health plan must be reasonably comprehensive, but may have different levels of covered services and co-payments.

<ol>
<li>What is considered “comparable coverage” necessary to obtain a waiver from the SHP?</li>
</ol>

The health plan must provide reasonably comprehensive coverage of health services, including preventive and primary care, emergency services, surgical services hospitalization benefit, ambulatory patient services, and mental health services

martina99 · November 7, 2012, 6:27pm

MA minimal credible coverage criteria:

<a href=“https://www.bluecrossma.com/common/en_US/pdfs/minimum-creditable-coverage-standards.pdf[/url]”>https://www.bluecrossma.com/common/en_US/pdfs/minimum-creditable-coverage-standards.pdf</a>

Apologies accepted.

BCEagle91 · November 7, 2012, 7:31pm

Sorry, I thought that I had posted a link to the actual law. It turns out that I emailed the law link to others.

Here is a link to the law:

<a href=“Redirect Notice”>Redirect Notice;

The law on waivers which is more specific than the web page:

(2) Comparable Coverage. (a) Coverage under a health benefit plan is comparable if:

the health benefit plan provides to the student throughout the school year reasonably comprehensive coverage of health services, including preventive and primary care, emergency services, surgical services, hospitalization benefits, ambulatory patient services, and mental health services; and

Note the word “including”.

The requirements for a school’s Student Health Program:

(3) Permissible Exclusions and Limitations. A school’s Student Health Program may (a) impose reasonable exclusions and limitations including different benefit levels for in-network and out-of-network providers; (b) impose reasonable co-payments and deductibles. The school’s Student Health Program must specify the co-pay amount for in-network and out-of-network office, clinic, and hospital visits. The total annual deductible may not exceed $250 per year.

…

The law states that those are necessary but it doesn’t state that they are sufficient.

There is no mention of HD plans in the law.

This is straight from the law and these are explicit cases of non-coverage but the section (3.05 (2)) indicates that this list isn’t complete in when a school may not waive participation.

BTW, the responsibility is the student “to determine whether the student’s health benefit plan has coverage comparable to the coverge offered under his or her school’s Student Health Program”.

Deductibles aren’t listed as being permitted to vary here. It’s interesting that (16) isn’t mentioned in the law. The only menion of co-payments is in conjunction with deductibles where it explicitly states that “the total annual deductible may not exceed $250 per year”.

Right, “including”.

At the bottom of that document:

"For 2009, the Following Shall Be Deemed to Be Providing Minimum Creditable Coverage:
• A health benefit plan that is a young adult plan, as defined in M.G.L. c. 176J, section 10
• Any health benefit coverage defined as creditable coverage in M.G.L. c. 111M, section 1(b)-(l)
• Any high-deductible health plan (HDHP) that complies with federal statutory and regulatory requirements for health savings accounts (HSA) under 26 U.S.C. section 223
• Any health arrangement provided by established religious organizations comprised of individuals with sincerely held beliefs
• Commonwealth Care Health Insurance plans, as established by M.G.L. c. 118H

This information is being provided for general informational purposes and is not intended
to be interpreted as legal advice."

So the minimum creditable coverage is to be found in the four referenced areas of the quoted law.

I often see clarifications of laws in documents but you usually can’t get a real feel without reading the law. The clarifications dumb things down so the average person can read it but often leave out details.

martina99 · November 7, 2012, 7:55pm

From my reading of the quoted law, it says the SHP deductible may not exceed $250. Not your policy. Your policy must meet the minimum threshold, which says nothing about a $250 deductible.

Edit:

Do not confuse regulations for SHPs and the minimal thresholds for coverage. Two different things. You have to meet the minimum threshold.

BCEagle91 · November 7, 2012, 8:00pm

The problem is that of the waiver for Comparable Coverage.

Northeastern University has the requirement of the $250 deductible limit to waive their student health plan. The other manager has a daughter at MIT and he determined that he couldn’t choose an HSA based on MIT’s requirements. I saw the Northeastern webpage with the requirement but only heard about MIT from the manager.

It is possible that schools are interpreting the law differently.

geeps20 · November 7, 2012, 8:05pm

BCEagle…you might be confusing coverage a student’s plan must have with deductibles.

In HD plans, all those things mentioned in your post are usually “covered”…they are just subject to different deductibles. HD plans do pass the MA law stated…that’s all the schools are looking for IMHO.

I’m confident in saying that the $250 limit is the limit for any plan the school is sponsoring, not for the waiver of one’s own plan.

BCEagle91 · November 7, 2012, 8:07pm

Northeastern has the deductible requirement to waive their own student health plan. I have two other managers that have confirmed this and have seen one school website personally.

geeps20 · November 7, 2012, 8:14pm

that may be the case. I wasn’t aware you saw a school’s website specifically state that your policy couldn’t have a deductible higher than $250. From reading the law, I would say they are indeed interpreting it wrong…If someone has a plan that meets the MA law requirement, then that should be good enough…that is just common sense IMO.

martina99 · November 7, 2012, 8:24pm

I believe the schools do have different requirements. I checked the MIT website, and they require coverage meeting or exceeding the SHP.

UMass requires coverage that meets the state minimum threshold:

<a href=“http://www.umass.edu/uhs/insurance/ship/[/url]”>http://www.umass.edu/uhs/insurance/ship/</a>

SteveMA · November 7, 2012, 9:06pm

BCEagle91–“If a SHP limits benefits per illness or accident, the minimum aggregate indemnity to be paid for all benefits for each physical or mental illness or accident may not be less than $50,000 per year; the total annual deductibles may not exceed $250 per year.”

What this is saying is that the policy has to have no greater than a $250 PER INCIDENT deductible and has to have at least $50,000 in total coverage per year. Your work policies have unlimited coverage, meaning their is no max how much these plans will pay out. This is defining these limited health plans. Typically you see companies offer these in hair salons, retail part time worker policies, etc. Your plan is JUST FINE for coverage in MA.

BCEagle91 · November 7, 2012, 9:17pm

I have no idea how you can translate “may not exceed $250 per year” to “no greater than $250 per incident”.

A couple of managers at my office translated the requirements on their school insurance websites the same way. They brought it to my attention.

SteveMA · November 8, 2012, 7:22am

BCEagle91–you do realize that you are confusing two things here-first shows what minimal coverage is needed to waive the plan and second is the state’s requirement for what the college sponsored SHP (student health plans) MUST cover at a minimum?

BCEagle91 · November 8, 2012, 8:37am

You do understand what the rest of the law says about comparable plans, right?

You do understand that two schools do have the deductible limits in place to waive their SHPs, right?

Are you a lawyer?

martina99 · November 8, 2012, 11:45am

Ok this is making my head hurt. It seems obvious to me, but maybe I’m missing something?

MA has regulations governing SHP’s, which include a deductible requirement.

MA has minimum threshold requirements for health insurance, which does not have a deductible requirement.

Some schools chose to require coverage that meets the SHP’S requirement. This is a school policy, not something required by MA regulations.

In my son’s case, UMass requires coverage meeting the MA minimum threshold, which is the minimum required by law.

I would question a policy that required us to spend thousands of dollars extra per year for superfluous coverage not required by law.

Health Insurance Increases

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