Since September of 1989, Massachusetts law, G.L. c.15A, ß 18, has required every full-time and part-time student enrolled in an institution of higher learning in Massachusetts to participate in a student health program or in a health benefit plan with comparable coverage. A part-time student is defined as a student participating in at least 75% of the full-time curriculum.
The Division of Health Care Finance and Policy's (Division) regulation, 114.6 CMR 3.00: Student Health Insurance, implements the student health requirement and sets forth the minimum benefit levels and required services for a Student Health Program (SHP). The regulation also establishes the criteria by which a school may waive a student's participation in SHP upon demonstration of comparable insurance coverage.
The minimum benefit levels and services that are required for student health plans are set forth in the SHP regulation. Some of these benefits and services are as follows:
- A SHP must provide reasonably comprehensive coverage of health services, including preventive and primary care, emergency services, hospitalization benefits, ambulatory patient services and mental health services
- Carriers must provide all benefits and services required by the Division of Insurance statutes and regulations
- 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.
One of the primary reasons for a mandatory SHP in Massachusetts is to promote students' access to quality and comprehensive health insurance. As a result, institutions of higher learning will automatically bill full-time and part-time students for individual membership in the health insurance plan sponsored by the colleges or universities. Students must purchase the school sponsored SHP or show proof of comparable coverage in an alternate health plan in order to enroll in Massachusetts colleges and universities.
If a student has an alternate health plan with comparable coverage through his/her parents, spouse, or employer, the student may request a waiver from participating in the college sponsored SHP. However, for an alternate health plan to be comparable to the SHP:
- The plan must provide to the student reasonably comprehensive coverage of health services, including preventive and primary care, emergency services, hospitalization benefits, ambulatory patient services and mental health services throughout the school year
- The services covered under the alternate health plan must be reasonably accessible for all health services to the student in the area where the student attends school.
The burden of proof that the alternate insurance is adequate falls on the student. Many students have insurance coverage through their parents, spouse, or employer. However, a health plan through a closed network of providers and accessible only for emergency services is not comparable coverage. Students and parents should be aware of this very important fact. If you have any questions regarding the Student Health Program, please call the Division at 800-609-7232.
Student Health Plan Reports
Student Health Program (SHP) reports include financial and performance metric analysis as well as enrollment and carrier information.
- Academic Year 2009-2010 (PDF) file size 1MB
- Academic Year 2008-2009 (PDF)
- Academic Years 2005-2008 (PPT) file size 1MB
1. What is the Student Health Program?
Massachusetts law requires that students enrolled in a certificate, diploma or degree granting program in a Massachusetts college, university or other institution of higher learning participate in a school-sponsored student health program (SHP) or an alternate health plan with comparable coverage. The law is M.G.L. c. 15A, ß 18, and the Division of Health Care Finance and Policy has issued student health regulations in 114.6 CMR 3.00: Student Health Insurance.
2. Which students are required to have health insurance?
The law requires all full-time students and part-time students registered for 75% of a full-time curriculum to have health insurance. The number of quarterly, trimester, or semester credits that constitute a full-time curriculum (or 75% of a full-time curriculum) varies from school to school. Students should check with their school to learn how its administrators determine the credit requirements. The law permits schools to grant a waiver from the SHP plan if the student demonstrates that he or she has comparable coverage under another insurance plan.
3. Are students required to have health insurance in order to enroll in Massachusetts colleges and universities?
Yes. Massachusetts institutions of higher education are required either to enroll students required to comply with the SHP requirement in the school-sponsored SHP plan or to require the student to verify comparable coverage.
4. Are students registered for a full-time load of online courses subject to the SHP requirement?
No. Currently, any student registered in an online program in Massachusetts, regardless of that studentís state of residency, is not required to participate in the SHP plan or an alternate health plan of comparable coverage.
5. Can students enrolled in credit-granting, short-term courses (defined as no more than 15 days of classes for each semester of 30 days total for the entire school year) waive out of SHP?
Yes. The Division is temporarily allowing schools to waive the requirement to purchase student health insurance for students enrolled in short-term courses for the current 2009ñ2010 school year. The Division is currently reviewing the SHP regulation and hope to provide better guidance on this issue for future school years.
For students enrolled in short-term courses that last longer than 15 days per semester or 30 days for the entire school year, please call the Division at 800-609-7232 for further guidance.
6. Are students enrolled in non-degree granting certificate programs (i.e. students receives only a certificate of participation, with no credits granted, for completing a class or program) required to enroll in SHP?
No. Students are only required to enroll in SHP if they are earning credits in a degree-granting program.
7. Can students with Commonwealth Care plans waive out of SHP?
No. Students who are subject to the SHP requirement are not eligible for Commonwealth Care. Students may obtain health insurance through their parentsí or spouse's health insurance, health insurance offered by their employer, the schoolís SHP plan or enroll in a Commonwealth Choice plan.
Commonwealth Choice offers a wide range of commercial health insurance plans. There are special Young Adults Plans for 18 to 26 year-olds. Please visit the Commonwealth Connectorís website ( www.MAhealthconnector.org) for more details.
8. What makes an insurance carrier a U.S.-based carrier?
A U.S.-based carrier means that the insurance carrier issuing the plan is a U.S. or domestic company, regardless of where the policy is purchased or where the claims are processed. Carriers outside of the U.S. means foreign or foreign-based insurance companies (i.e., non-domestic or non-U.S. companies), including those companies with satellite offices in the United States.
Foreign Insurance Companies with U.S. Subsidiaries
Some foreign insurance companies have numerous companies and subsidiaries worldwide. A foreign carrier may have a U.S. subsidiary, as well as subsidiaries in other countries. Policies purchased from the U.S. subsidiary qualify for a waiver, but policies purchased from foreign subsidiaries do not qualify for a waiver (unless the ìforeign study abroadî exception applies).
Foreign Insurance Companies with U.S. Satellite Offices
Insurance carriers that are based in a foreign country, but have a U.S. satellite office are considered foreign or foreign-based insurance companies. Their health plans are ineligible for a waiver unless the ìforeign study abroadî exception applies.
9. How does a student without health insurance enroll in SHP?
The school will automatically enroll the student in the SHP and include the cost of the insurance in the tuition bill.
10. What health services are covered by a SHP plan?
SHPs are required to 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. SHPs offered by Massachusetts insurance carriers must include all benefits mandated by Massachusetts law. If the school's SHP limits benefits per illness or accident, the maximum aggregate indemnity to be paid for all benefits for each physical or mental illness or accident must be at least $50,000 for each year.
11. Are there limits on co-payments and deductibles?
There are no limits on co-payments. The regulation permits institutions to impose reasonable co-payments and requires that the SHP plan to specify the co-pay amount for in network and out-of network office, clinic and hospital visits. However, there is a limit on deductibles. If an institution chooses to impose reasonable deductible, the annual deductible for SHP plan may not exceed $250.
12. Do SHP plans cover pre-existing conditions?
A pre-existing condition is any condition which originates, is diagnosed, treated or recommended for treatment within the six months prior to the insuredís effective date under the policy. For SHPs offered by Massachusetts licensed insurance carriers, a pre-existing condition must be covered no later than six months from the coverage effective date. This requirement applies to the SHP of most schools.
13. Is a SHP plan effective only during the school year?
The student health policies are effective for a one year or 52-week period. For most schools, students are covered from September 1 to August 31. Some schoolsí policies, however, are effective from August 1 to July 31. Students should check with their school or the school's SHP brochure to confirm the coverage period.
14. What is required for a student to obtain a waiver from the SHP plan for alternative coverage?
The student must submit a waiver application to the school and certify, in writing, that he or she has alternative coverage, the name of the entity offering the plan, the policy number or member identification number, the name of the subscriber or primary enrollee and the relationship of that person to the student, and a statement that the coverage is comparable to the coverage required under a SHP. The waiver request must be on a form supplied by the institution, and may be submitted electronically.
15. What is considered "comparable coverage" necessary to obtain a waiver from the SHP?
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; and be reasonably accessible to the student in the area where the student attends school (see section 3.05 (2) of the regulation).
16. Is the alternate health insurance plan required to meet all the criteria of a SHP plan to be considered "comparable coverage"?
No. The health plan must be reasonably comprehensive, but may have different levels of covered services and co-payments.
17. Is a school required to grant a waiver request if a student's alternative health plan meets the conditions for a waiver?
No. Schools may require students to enroll in the school-sponsored SHP in order to enroll at the institution.
18. What types of health insurance plans are not considered comparable coverage?
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.
19. Is MassHealth a comparable coverage plan?
Yes. A school may grant a waiver to a student enrolled in MassHealth.
20. May a school grant a waiver to international students on scholarships (such as the Fulbright Scholarship) with an insurance plan from a U.S based carrier or the US government that does not meet all of the specified requirements for SHPs?
As noted above, the SHP regulation does not impose all of the requirements specified for SHP upon alternate health plans. Schools have discretion to grant a waiver if the coverage is reasonably comprehensive.
21. Can a Massachusetts student apply for the Health Safety Net?
Low-income students who are eligible and enrolled in their schoolís SHP may apply and be eligible for the Health Safety Net. These individuals would be eligible for Health Safety Net Secondary which would only pay for medically necessary services at Massachusetts acute hospitals and community health centers that are not covered by their primary insurance. Students who are eligible but not enrolled in their schoolís SHP (and do not have a waiver from their school) are not eligible for the Health Safety Net.
Student Health Insurance Filing Information
The Divisionís regulation, 114.6 CMR 3.00: Student Health Insurance Program, implements the student health insurance requirement mandated by M.G.L. c. 15A, ß18 and requires schools to submit information during each school year that summarizes student participation in the Student Health Program (SHP).
The Division collects this information using various SHP-related surveys that can be accessed on DHCFP-NET , the Divisionís web-based reporting tool. The chart below summarizes the reporting requirements for schools in the upcoming school years.
2011-2012 Fall Enrollment Survey
2011-2012 Benefit Survey
2010-2011 Performance Metrics
2012-2013 Fall Enrollment
2012-2013 Benefit Survey
2011-2012 Performance Metrics
2013-2014 Fall Enrollment
2013-2014 Benefit Survey
2012-2013 Performance Metrics
As a part of the Benefit Survey submission, SHP filers are also required to submit an electronic version of their SHP evidence of coverage or a description of the benefits, benefit levels, exclusions, limitations and other important terms and conditions of their school's SHP (similar to that which the Division requires schools to make available to students online). The insurance plan description can be emailed to the Division at HCF.firstname.lastname@example.org.
If you have any questions regarding the filing of the SHP information, please contact the DHCFP Help Desk at 800-609-7232.