When Health Costs Harm Your Credit

By ELISABETH ROSENTHAL New York Times

This is an excellent article outlining the problems people can run into by allowing medical bills to go unpaid. It takes a long time to decipher what you actually owe, but providers can report you to credit agencies for late payment very quickly.  People in these types of situations have reason to worry.

LIKE most people, I am generally vigilant about paying my bills — credit cards, mortgage, cellphone and so on. But medical bills have a different trajectory. I (usually) open the envelopes and peruse the amalgam of codes and charges. I sigh or swear. And set them aside for when I have time to clarify the confusion: An out-of-network charge from a doctor I know is in-network? An un-itemized laboratory bill from a doctor I’ve never heard of? A bill for a huge charge before my insurer has paid its yet unknown portion of a hospital’s unknowable fee?

I would never countenance the phrase “60 days past due” on my Visa card statement. But medical bills? Well… with the complex negotiations that determine my ultimate payment, it often takes months to understand what I actually owe.

Unfortunately, I may be playing a dangerous game. Mounting evidence shows that chaos in medical billing is not just affecting our health care but dinging the financial reputation of many Americans: While the bills themselves frequently take months to sort out, medical debts can be reported rapidly to credit agencies, and often without notification. And even small unpaid bills can severely damage credit ratings.

A mortgage initiator in Texas, Rodney Anderson of Supreme Lending, recently looked at the credit records of 5,000 applicants and found that 40 percent had medical debt in collection, with the average around $400; even worse, most applicants were unaware of their debt. Richard Cordray, director of the federal Consumer Financial Protection Bureau, has noted that half of all accounts reported by collection agencies now come from medical bills, and the credit record of one in five Americans is affected.

A single medical bill reported to a credit agency can easily become a “millstone around your neck” said Mark Rukavina, principal at Community Health Advisors, a health care advisory service. He added: “It will take a long time to make that right, even once the bill is paid. I’ve had mortgage brokers call me and say ‘I have these people with great credit. They’ve refinanced before, but now they’ve got this medical bill and even though they’ve paid it off, I can’t get them a good rate.’ ”

Part of the problem is that there are few standards governing medical debts: One billing office might give you — or your insurer — 60 days to pay before pursuing collection. Another might allow you to pay off a bill slowly over a year. Many will sell the debt to collection companies, which typically take a cut of the proceeds and decide when or whether to report unpaid debt to credit agencies.

The problem is accelerating for several reasons. Charges are rising. Insurance policies are requiring more patient outlays in the form of higher deductibles and co-payments. More important, perhaps, is that while doctors’ practices traditionally worked out deals for patients who had trouble paying, today many doctors work for large professionally managed groups and hospital systems whose bills are generated far away, by computer.

Both Congress and the protection bureau have been trying to better insulate patient credit scores from the inefficiencies of our market-based medical system. Various proposals have been considered to differentiate medical debt from other forms; it could be erased once it has been paid off or not reported to credit agencies at all, for example. So far, the credit industry has fought successfully against such efforts, noting that they could allow some genuine scofflaws to evade legitimate charges. But it’s also good business, since health care bills are now the largest source of business for collection companies, according to consumer protection agency officials.

Having spent the last year reporting a series on American health costs, I’ve heard plenty about credit casualties.

Gene Cavallo, 61, a New Mexico businessman who put his children through college, had always paid his bills promptly and had an excellent credit rating, until he required surgical excision of a melanoma on his shin two years ago. The more than 60 bills generated for the surgery and six months of follow-up visits — arriving sporadically and ranging from 18 cents to $17,000 — came to $110,000; his insurance covered about $70,000.

When various providers asked him to pay the remaining $40,000, he requested itemized bills and balked at some of the “ridiculously inflated prices,” such as $85 for tweezers and $20 for a box of tissues. He argued the bills point by point, and ultimately agreed to pay $25,000.
But during the negotiations some of the debt was sent to collection. Two years later, he no longer answers the daily robocalls from collection agencies and has had a couple of credit cards canceled because his score has fallen. “It was a scary thing to do because I own a business and dabble in real estate, so the ability to borrow has always been important to me. And now I have no ability, I assume, to borrow for any reason.”
Michael S., who declined to give his full name so as to protect his reputation with business clients, had to declare bankruptcy in Wisconsin more than five years ago after a fraught year in which his toddler was evaluated for what proved to be a benign neurological condition that required no treatment: “You’d get bills for several different doctors’ groups and for tests and M.R.I.s and you don’t know what they are. I was having trouble figuring out who we owed what. And then, if it goes to collection, then suddenly they’re saying we need this paid now.”

With medical expenses, unlike most other purchases, you generally don’t know the price the hospital will charge in advance. And the subsequent bills and insurance statements — so-called explanations of benefits — are often layered in obfuscation and pressure tactics.

Consider Chris Sullivan of Pennsylvania, whose $2,770 bill for an echocardiogram offered a “prompt payment” discount of 20 percent if he wrote a check within 21 days — meaning a discount for not asking questions on a bill for a test he was told would be under $300.

Another “explanation of benefits” statement notified Joe Cotugno of New York City that his two-day hospital stay for a hip replacement was billed at $99,469.70 (doctors’ fees not included). Cigna paid $68,420.53 after knocking off some $28,000 and requiring Mr. Cotugno to pay $3,018.41. So, it informed him, “You saved 96 percent.” Huh?

The Consumer Financial Protection Bureau has been studying the impact of medical billing on credit scores since 2012, acknowledging that unpaid medical bills in collection “frequently end up on consumer credit reports,” as an outgrowth of “very complex and confusing systems of figuring out who owes what after a medical procedure.” Mr. Cordray, the bureau’s director, said it would take appropriate action if harmful practices were identified.

Bills in Congress that would regulate the practices have been stalled for years. The Medical Debt Relief Act was passed by the House in 2010, but never made it to a Senate vote. After a modified version of the bill failed to pass again last year, another act was recently introduced in the Senate and House.

Meanwhile, patients are right to worry. When Matt Meyer, who owns a saddle-fitting company in New Hampshire, set up a monthly payment plan after some surgery, he was distressed to notice that the invoices came from a debt collector. “I had no idea this was considered debt,” he said, and wondered: “Are they reporting that” to a credit agency?

Good question.

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Three Ways to Slash Your Medical Bills

Medical Cost Advocate’s CEO Derek Fitteron was recently interviewed for Fox Business. Read the following BLOG post to learn more about reducing medical costs. Dont forget to negotiate your medical bills and save money. It’s worth the effort. In these difficult economic times, why pay list price when you may be able to save.

By: Donna Fuscaldo

FOXBusiness

Published July 10, 2012

Many things in life are negotiable, including medical bills.

“More and more billing offices, whether it’s a hospital or doctor’s office, are much more receptive to bargaining,” says Nancy Fase Guernon, director of operations at CareCounsel, an health advocacy firm. “There’s definitely ways to negotiate the bill.”

 According to a survey of Angie’s List members who asked for discounts from their doctors, 74% said they were successful. “We’ve heard some great success stories from members who have successfully negotiated with their health care provider,” says Angie Hicks, founder of the peer-review website. “It doesn’t hurt to ask. You’ll be amazed at what you can save and still get great care.”

 From making sure your bill is correct to negotiating ahead of a procedure there are ways to get as much as 40% off your medical bill. Here’s how:

Step One: Check the accuracy of the bill

Medical billing mistakes are common, so review the invoice carefully before submitting payment.  Experts say it’s common for a procedure to be coded wrong by the doctor’s office and lead to excess charges.

 Patients should review their health insurance plan to know what is and is not covered. “You want to make sure if it’s the insurance company’s responsibility to pay it, it’s paying what it should according to the plan,” says Fase Guernon.

 If you don’t have insurance or are going out of network and are paying out of pocket, Derek Fitteron, founder and CEO of Medical Cost Advocate, advises getting a full cost estimate of the procedure upfront to avoid any surprises at the end and you avoid getting overcharged.

 Fitteron also suggests asking for an itemized bill so you can review the charge for every procedure. “Sometimes there are mistakes and those mistakes might include bills for the wrong procedures or procedures that didn’t happen.”

 Step Two: Negotiate Up Front

Think of negotiating health care like shopping for a car. A dealership wants your business and will working with you—same idea applies to a doctor. For instance, many times doctors will reduce their price if you pay in cash or pay for the procedure ahead of time.

 According to Hicks, some hospitals and doctors will cut a health-care bill by as much as 50% if you pay in cash on the day of service. “We had a member from Washington D.C. who saved $9,000 on his mother’s in-home care by bargaining ahead of her treatment.”

 To negotiate ahead of time, experts say it pays to do your homework. Procedure prices vary be region, so know what know what is common in your area before negotiating. “Do the research so you are not throwing out numbers. That can be insulting,” says Fitteron.

 Step Three: Be honest about your financial situation

 If you get hit with a medical bill that you can’t afford, the best thing to do is call your doctor or hospital and honestly explain your financial situation. Often times the medical facility will be willing to reduce the bill as long as you agree to pay something.

 “If you ask the billing office for a discount and you are willing to pay something right then more times than not they will knock down the bill 30% to 40%,” says Fase Guernon.

 Some providers will set up interest-free payment plans. Hicks points to one member who saved $4,000 by talking to her doctor about her financial concerns. The member couldn’t afford the costs that weren’t covered by the insurer so the doctor agreed to collect just the insurance portion, she says.

 “Too many consumers aren’t aware of just how much power they have to negotiate their health-care costs. There are many great doctors, dentists and other health-care specialists out there who are willing and eager to work with their patients to provide them with high quality, affordable care,” says Hicks.

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Why Health Care Costs Keep Rising: What You Need to Know

ABC News

By HUMA KHAN

The below article provides some insights as to why healthcare costs continue to rise. Check it out!

Republicans and Democrats may disagree on what a health care bill should include, but both parties agree that dramatically rising health care costs need to be contained.

The U.S. government spent more than $2.3 trillion on health care in 2008, more than three times the $714 billion spent in 1990, according to the Kaiser Family Foundation. In 2008, U.S. health care spending averaged $7,681 per person in 2008.

To put that into perspective, the United States spends twice as much on health care as it does on food, according to the McKinsey Global Institute, even though the prevalence of disease is relatively less than in comparable countries.

At the same time, for consumers, premiums continue to rise sharply. Since 1999, they have increased 131 percent for employer-sponsored health coverage, according to Kaiser. Stories of families facing unaffordable premium hikes can be found across the country.

Health care costs are partly so high because they have been increasing rapidly,” said Stuart Guterman, assistant vice president for the Commonwealth Fund’s Program on Payment System Reform. “There’s a long list of factors like technology and the organization of health care that doesn’t promote efficient and effective care.”

Despite President Obama’s bipartisan health care summit last month, both parties continue to bicker about what should be included in a health care bill, with each side presenting its own argument on what specific health care costs should be contained.

Some experts argue that while the health care bill, as proposed by Obama and congressional Democrats, expands benefits and seeks to implement insurance reforms that would open up coverage to a wider scope of people, it does not address the core issues behind rising health care costs. Proponents of the legislation argue that it is a start and creates the foundation for sustainable changes in the long term.

Here are some of the drivers of cost increases: (more…)

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Healthcare Costs Rise, According to S&P Indices

Healthcare Financial Management Association

Healthcare costs continue to rise. Even though the rate of increase may have slowed, costs nonetheless continue to rise.

The average per capita cost of healthcare services covered by commercial insurance and Medicare programs increased by 6.19 percent over the 12-month period ending in February, as measured by the Standard & Poor’s (S&P) Healthcare Economic Composite Index.

Healthcare costs covered by commercial insurance rose by 7.97 percent and Medicare claim costs rose at an annual rate of 3.22 percent, according to the S&P indices. Overall healthcare costs continue to increase at a slower rate, according to the index. In the six-year history of the Composite Index, the highest annual growth rate was 8.74 percent in May 2010. With a 6.19 percent increase in February, claims costs growth rates have declined 2.5 percent in nine months.

The indices estimate the per capita change in revenues accrued each month by hospital and professional services facilities for services provided to Medicare patients and patients covered under commercial health insurance programs. The annual growth rates are determined by calculating a percentage change of the 12-month moving averages of the index levels compared with the same month of the prior year.

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Rising Cost Tops Employees’ Health Care Worries


Employers are still concerned about the rising cost of healthcare. Will there be any end in sight?

By Stephen Miller

U.S. employees’ greatest concerns about health care are rising costs, canceled coverage and new taxes on medical benefits. Their employers are most concerned about the lack of federal guidance on what requirements must be communicated to employees, according to a December 2010 survey by HighRoads, a benefits administration service provider.

“There appears to be a healthy skepticism on the employer’s part about the content and timing of guidance from the federal government on how to administer and communicate future plan changes,” said Kim Buckey, practice lead at HighRoads. “While most employers increased their communications efforts during the fall 2010 open enrollment period to communicate changes required by health care reform, there are still doubts about how effective those communications were.”

Buckey advised, “There is clearly an opportunity to do some follow-up communications—based on the actual employee elections during open enrollment—or employee sensing (surveys or focus groups) midyear to determine whether employees truly understood the impact of the year’s plan changes.”

Employees’ Concerns

The biggest concerns HR professionals and benefits managers are hearing from employees about how health care reform affects them, HighRoads found, include:

• Increased cost of coverage (noted by 50 percent of respondents).

• Cancellation of benefits (13 percent).

• Government taxation of medical benefits (13 percent).

• Ability to add adult dependents (12 percent).

• No real concerns (12 percent).

Increased Communications

While 88 percent of employers reported that they had increased their employee communications to address health care reform, many still worried that the communications might not have been enough. The biggest communications concerns employers had around health care reform for the year ahead include:

• Lack of federal guidance on what the requirements are or how any changes in guidance during the year might change what has been communicated to employees (25 percent).

• The disconnect on cost and existing plans, because the law is predicated on being cost neutral to taxpayers and allowing employees to not lose the coverage they have (13 percent).

• Making sure that employees are told everything that is changing under their plans (13 percent).

• Employee understanding of changes and how the changes affect them (12 percent).

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Health care’s hidden costs: $363 billion

Consumers beware of the hidden or extra costs associated with healthcare not covered by insurance or traditional Medicare. A recent article states that consumers are paying even more than was expected for out-of-pocket costs. The most alarming fact is that the average household income fell 1.9% in 2010 while health care costs rose 6%.

CNN Money

By Parija Kavilanz

A year after the passing of health reform, a new industry report revealed that consumers may be paying billions of dollars more in out-of-pocket health care expenses than was previously thought.

These “hidden” costs of health care — like taking time off to care for elderly parents — add up to $363 billion, according to a report from the Deloitte Center for Health Solutions, a research group.

That amounts to $1,355 per consumer, on top of the $8,000 the government says people spend on doctor fees and hospital care.

“We’re surprised that this number came in so high. It’s significant,” said Paul Keckley, executive director with the group.

The out-of-pocket costs that the government tallies usually include only insurance-related costs like premiums, deductibles, and co-payments.

Keckley said the study is the first to estimate how much consumers dish out on health care related goods and services not covered by private or government insurance.

These include: ambulance services, alternative medicines, nutritional products and vitamins, weight-loss centers and supervisory care of elderly family members.

“These costs can add up to billions of dollars, even eclipsing housing as a household expense,” said Keckley.

The Deloitte study found that half the hidden costs are for supervisory care, or the unpaid care given by family and friends.

“We compared on an hourly basis the average number of hours per month taken off work to look after a family member or friend, and lost wages in doing this,” said Keckley.

The report estimates the value of unpaid care is $12.60 per hour, or $199 billion a year.

“It has been one year since the passage of health care reform,” said Keckley. “We wanted to understand the financial context behind decisions that consumers are making about how they spend their money on health care.”

0:00 /2:22Humana deals with health care reform

As health reform rolls out over the next few years, Keckley expects that out-of-pocket health care costs to consumers will increase quickly. Health care costs continue to rise faster than household incomes and insurers are passing along more costs to their customers.

The average household income fell 1.9% last year while health care costs rose 6%, he said.

“This is a perfect storm in which consumers’ hidden costs will only increase exponentially in the near future.”

The Deloitte study looked at the most recently available health care expenditure data from the government. The firm, with Harris Interactive, also polled 1,008 U.S. adults,18 and older, between Sept. 29 to Oct. 4, 2010.

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Retirement confidence falls to all-time low

A recent survey reveals that most Americans still don’t save enough for retirement. If the facts are correct, it appears that the majority of Americans will be working well past the age of 65.

By Larry Barrett

March 16, 2011

Most Americans still aren’t saving anywhere near enough money to afford the dignified retirement they all claim is so important to them. Even worse, most don’t even have any idea exactly how much they’ll need if they were to begin saving today for their golden years.

That’s the sobering truth derived from the 21st installment of the Employee Benefit Research Institute’s Retirement Confidence Survey (RCS) released Tuesday.

The only good news, according to Jack VanDerhei, research director of the Washington, D.C.-based EBRI, is that the majority of Americans are rightfully ignoring short-term economic improvements in the stock market and unemployment rates following several years of dismal performance. They now recognize that they are woefully behind the eight-ball in terms of properly planning and saving for their eventual retirement.

“There are many big, systemic factors redefining retirement in America today,” VanDerhei said during a conference call with reporters. “People are starting to wake up to this reality and changing their expectation of retirement. Unfortunately, the survey doesn’t find any evidence that people are changing their behavior — at least not yet.”

The RCS survey, conducted by market research firm Mathew Greenwald & Associates, found that more than half of the 1,260 respondents surveyed in January 2011 are “not all confident” or “not too confident” that they’ll be able to afford the retirement they want, the lowest level of confidence among workers in the survey’s 21-year history.

One of the main reasons so many people are so pessimistic about their retirement prospects is the simple fact that far too few workers are actually saving for retirement.

Currently, most Americans can expect an average retirement of about 20 years, and that number continues to expand as people live longer, while at the same time incur higher medical and cost-of-living expenses.

The survey found that the folks with savings of less than $25,000 are the most petrified about retirement and essentially resigned to the fact that they’ll either work throughout most of their retirement or never really experience one at all.

Forty-three percent of respondents with savings of less than $25,000 said they are not confident they’ll have enough money to afford a decent retirement, up from 19% in 2007.

Meanwhile, 22% of those with between $25,000 and $100,000 in savings remained less-than-confident about their retirements, more than triple the 7% who felt the same way in 2007.

This changing perception reflects not only most Americans’ disinterest in saving for tomorrow, but also the stark reality that most people aren’t expecting things to magically improve between now and the time they hit retirement age.

“Sixty-two percent of workers said they can save more than they’re saving now,” said Greenwald. “Most said they could dine out less, cut back on entertainment and, in some cases, wouldn’t really need to cut back at all to increase their savings. And while the sacrifices wouldn’t be that great, many still haven’t formed the habit of doing it.”

That so few have taken the time to reasonably figure out how much they’ll need to take that cruise to Alaska or keep them in prescription medications for 25 years or more speaks to just how invaluable retirement planning advice will be to this growing population of skeptical, unprepared workers.

Perhaps most depressing, the survey found that the percentage of workers who expect to retire after age 65 continues to increase, growing from 11% in 1991 and 20% in 2001 to a stunning 36% in 2011. Also, 74% of workers said they expect to have work for pay in retirement, more than triple the number (23%) of current retirees who are now working because they need the income.

“Even those who have achieved the highest levels of accumulation already, with more than $100,000 in savings, won’t be able to maintain the lifestyle they’re currently enjoying in retirement,” Greenwald said. “High accumulators still haven’t come to that reality. And 70% of all workers say they’re behind schedule when it comes to saving for retirement.”

“The bigger problem is that most haven’t changed their behavior and turned this pessimism into action to catch up,” he said.

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Medical bankruptcies a continuing problem, study finds

A recent survey reveals that medical bankruptcies continue to plague families in Massachusetts.

The Boston Globe

Kay Lazar, Globe Staff

The 2006 Massachusetts law that required nearly everyone to buy health insurance has not significantly staunched residents’ pain from medical bankruptcies, according to a new study.

A survey of Massachusetts residents who filed for bankruptcy in July 2009 found that 53 percent cited a medical cause, down from 59 percent who blamed a medical cause in a survey done in early 2007, before the state law had been fully implemented. But because of the small number of people surveyed, the difference was not statistically significant, according to the study in today’s American Journal of Medicine.

Lead study author Dr. David Himmelstein said medical bills are still causing bankruptcies because health costs in the state have continued rising sharply. High premium costs, along with large co-payments and deductibles, often expose families with insurance to substantial out-of-pocket costs, said Himmelstein, a professor of public health at City University of New York.

“People think they have reasonable insurance until they try and use it,” Himmelstein said. “You are carrying an umbrella and it starts to rain and you put it up and it’s full of holes. For most people, it just hasn’t rained yet.”

Himmelstein, who conducted the research while working as an associate professor of medicine at Harvard Medical School, is co-founder of Physicians for a National Health Program, an organization that pushes for national health insurance.

He said his findings suggest that the national health overhaul, which was largely modeled on the Massachusetts law and will take full effect in 2014, will not ease the number of medical bankruptcies, either.

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AARP survey finds N.J. seniors are facing financial, health care hardships

A recent survey by AARP reveals that many NJ senior citizens are having a hard time meeting their financial obligations and getting adequate health coverage. Healthcare costs continue to rise and benefits are shrinking. The fear is real as more and more seniors find themselves working well into their golden years in order to support themselves. Read the below article and review the survey.

Peter Van Ness used to be the picture of financial health: perfect credit scores, quick to pay down his credit cards, never late on bills. During 50 years of work, he said, not once did he need help making ends meet.

But he could use some help now.

“I am being buried,” said Van Ness, 67, of West Milford, who still works but must pay for his bedridden mother’s medical expenses, has three kids in college and won’t be getting any retirement benefits from his company.

“I have real problems even trying to supply food for the family,” he said. “Whoever said the golden years are your best years — I laugh like hell.”

Van Ness was one of 400 New Jersey residents over age 50 polled for a survey to be released today by the AARP. Like him, many of the respondents said they’re having a hard time meeting their financial obligations and getting adequate health coverage. About two-thirds said they don’t have all the resources or information they need to stay healthy, and three in four said they worry about the levels of Social Security and Medicare benefits.

“It shouldn’t be surprising that there’s real palpable fear out there because seniors are suffering,” said Douglas Johnston, legislative director for AARP-NJ. He said the state’s utility costs, for example, have risen for the last five or six years while Social Security payments, a major source of income, have remained flat the last two years.

“I frankly don’t know how they do it,” he said. “The median amount Social Security recipients get per year is $10,400. How do you live on $10,400 anywhere, especially an expensive state like New Jersey?”

Harry Padden of Irvington, 58, is nearing retirement from his job as an inspector for the U.S. Department of Housing and Urban Development, but he fears his pension may be cut before he leaves and said he’s already paying more for health care.

“I’m squeaking through paying my bills,” he said. “I’ve considered moving to Georgia or Florida — there’s higher wages and it costs you less. My daughter has indicated that if I go, she’s going to follow.”

The survey also found 84 percent of residents would prefer to get long-term care at home or in an assisted-living facility, as opposed to a nursing home. Johnston said the state could save money by investing more in home-based care, which he said costs one-third of what nursing homes cost.

“It gives people what they want, we’ve never met a legislator or governor who doesn’t agree — and yet it never seems to happen,” he said.

The AARP survey also asked New Jerseyans over 50 what they most want to do in their retirement years. Forty-two percent said travel, 23 percent said they would focus on hobbies and interests, 8 percent mentioned their jobs or careers and 6 percent said they would devote themselves to their families.

Though he talks of moving, Padden said spending time with his family was a major reason he’s still in New Jersey.

“My grandson is in a basketball team, and I don’t really miss a game,” he said. “I’m driving over now.”

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Major Reforms in Student Insurance Proposed

Looks like there may be some hope for college students regarding insurance coverage.  In an area that has long been neglected, Congress has now introduced new regs to the Affordable Care Act which will require colleges and universities to provide health insurance coverage to students.

By Ria Patel

In quest to make lives of University students better, the Congress has decided to introduce new plans in the existing health care law, which will be in effect from the next year.

The reforms proposed, will be in favor of college students, who have estimated number of 3 million at present.

Till now, the area of student insurance was widely neglected, partly because of its uncertain and short validity duration.

But now after, bringing the student health insurance plans offered by colleges and universities to the same level as that of the 2010 federal Affordable Care Act by the U. S. Department of Health and Human Services, the need for further amendments is strongly felt.

The new reforms will ask colleges and universities to provide the health insurance to students, even if they are less than 18 years or have underlying medical conditions like diabetes or other discrepancies.

The law will also take care of benefits borne out of student plans. The schemes, which currently have very less boons, will observe a boost to minimum of $100,000 before September 2012 and more than $2 million after that.

The Universities will also be asked to maintain the coverage, in case the student is down with ill-health. No student will be punished if he forgets to give a proper account of its medical history.

Meanwhile, the Health and Human Services Department has sought public comments and views on proposed amendments till April 12.

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