Q. Do student health care plans have to cover preventive care at no charge?
A. 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.
(Note that if the school has religious objections to contraception, it can offer a student health plan that doesn’t include coverage for contraceptives, even though contraception is normally a required benefit on 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.
This includes vaccination for COVID-19. Under special rules implemented by the CARES Act, private health insurance plans — including student health plans — had to start fully covering COVID-19 vaccination within 15 business days of the date the CDC’s vaccine committee made the recommendation; that happened in mid-December 2020, so student health plans were fully covering COVID vaccines by the end of 2020.
(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, 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.