Some Schools are considering whether SHIP enrollment can be extended beyond the term of its expiration for Students who have just graduated. Are these extensions of SHIP coverage permissible?
The Health Connector’s regulations at 956 CMR 8.00 only describe the obligation for Schools to offer a SHIP, and for Students to either enroll in the SHIP or waive the SHIP by demonstrating they have comparable coverage. To the degree Schools have questions about who may validly be considered eligible to enroll in the SHIP, the Health Connector encourages Schools to work with their health insurance carriers, Third-Party Administrators, and the Division of Insurance (as applicable) to ensure that enrollment flexibility and extension of coverage modifications are permitted and, if so, are clearly explained in SHIP evidences of coverage, are available according to clear and consistently applied standards across all eligible newly graduated students, and remain consistent with applicable state law and federal requirements, including 45 CFR § 147.145. Note: Student Health Insurance Program (SHIP) and COVID-19 Under 956 CMR 8.00, institutions of higher education, referred to as Schools in this Frequently Asked Question (FAQ), in Massachusetts are required to offer a Student Health Insurance Program (SHIP) to Students, and Students must either enroll in the SHIP or provide proof of comparable coverage. Due to the COVID-19 pandemic, some Schools are considering expanding remote coursework beginning in Academic Year (AY) 2020-2021, as well as arrangements to support graduating Students. This FAQ aims to help stakeholders understand options for Schools that are consistent with SHIP regulatory requirements as stakeholders consider the impact of a transition to remote learning or post-graduation arrangements on SHIP offerings and enrollment.