Federal regulators will continue to treat colleges and universities that help pay graduate student workers’ health insurance premiums more gently than they would treat an ordinary employer that paid workers’ individual health premiums.
The “tri agencies” — the U.S. Labor Department, the U.S. Treasury Department and the U.S. Department of Health and Human Services — first announced the temporary rules for grad student workers in 2012. They renewed the temporary rules earlier this year for insured or self-insured grad student coverage with plan years starting before Jan. 1, 2017.
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The tri-agencies developed the temporary rules to free colleges and universities from a strategy they developed to discourage ordinary employers from dropping group health coverage and giving workers cash to pay individual coverage.
The tri-agencies have classified cash-for-premiums arrangements at ordinary employers as group health plans. That means the arrangements would have to comply with all of the Affordable Care Act rules that apply to ordinary group health plans, such as the requirement that a group health plan cover ACA essential health benefits without imposing an annual or lifetime benefits cap.
Many colleges and universities help grad student workers, such as teaching assistants, get health coverage by helping the grad students pay for individual student health coverage. Some commenters told the tri-agencies that a grad student health coverage subsidy program is like the kind of ordinary employer’s cash-for-individual-premiums arrangement that the tri-agencies have blocked.
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