Student, short-term and other coverage with fewer rights

Some health coverage has far fewer protections than ordinary insurance. If you have a student plan, a short-term plan, a health care sharing ministry membership or a fixed indemnity product, the appeal path in most guides on this site may not apply to you. This page helps you work out where you stand. The reference pages are Student health plan and Short-term plan, sharing ministry and other non-compliant products.

What this means

Kind of coverage	Federal appeal and independent review rules
Student plan sold by an insurer through a college	Apply. It is treated as individual coverage.
Student plan the college funds itself	Not confirmed here. Largely left to state law.
Short-term, limited-duration insurance	Do not apply.
Fixed indemnity insurance	Do not apply.
Health care sharing ministry	None found.

The rows have different reasons.

• Student plan from an insurer. The federal rule on internal appeals and external review applies to it, as it does to other individual plans. Follow Marketplace and individual plans: the appeal path. A student plan the college pays claims on itself falls outside that definition, and this site has not checked how it is treated.
• Short-term insurance. It is left out of the federal definition of individual health insurance coverage. So the federal appeal and independent review rules, and the No Surprises Act, do not apply. Any appeal rights come from the policy and state law. The federal definition limits this insurance to no more than 3 months, or 4 months including renewals, with a warning notice. On 7 August 2025 the federal agencies said they do not intend to prioritize enforcing that definition while they write new rules. A proposed rule has not been found as of 11 November 2026.
• Fixed indemnity insurance. It pays a fixed dollar amount per day, per illness or per service, whatever the real expenses. It is an excepted benefit, so the federal health coverage requirements, including the appeal rule and the No Surprises Act, do not apply. This site has not confirmed whether an employer-sponsored fixed indemnity product must still follow the Employee Retirement Income Security Act (ERISA) general claims procedure.
• Health care sharing ministry. The tax code defines it as a tax-exempt organization whose members share medical expenses according to common beliefs. It is not treated as insurance by that definition. The Centers for Medicare & Medicaid Services (CMS) says the No Surprises Act does not apply. No federal appeal or external review rule was found. State treatment varies and was not checked.

What to do

1. Find out exactly what you have (you). Your member documents may use “plan”, “membership” or “program”. Ask the company in writing whether it is licensed as insurance in your state.
2. Read the contract for its appeal steps and deadlines (you). Write down the dates. The deadline in your contract may be shorter than the 180 days that federal rules give most plans.
3. Ask for the denial in writing and for the rule used (you). Use the claim file request letter. Ask for the section of the contract relied on.
4. File the company’s appeal on time (you). Send it so that you can prove the date of delivery.
5. Call your state insurance department (you). Say what kind of coverage you have and ask whether it regulates the company. See Complain to your state insurance department.
6. Look at other options (you). Ask a legal aid office or consumer advocate about the contract, a lawsuit under state law, and any state program. State consumer advocates and legal aid are good places to start.

Check the date on your notice, which controls.

The rule

Short-term, limited-duration insurance is not individual health insurance coverage under the federal definition, so the federal individual-market rules, including appeals and independent review, do not apply to it. (Title 42 of the United States Code (U.S.C.), section 300gg-91(b)(5))

Watch for

• “You can appeal like any insurance.” For short-term plans, sharing ministries and fixed indemnity products, the federal appeal and independent review rules do not apply. Do not count on a free outside reviewer.
• The 180-day figure. Short-term plans, sharing ministries, fixed indemnity products and non-ERISA grandfathered policies follow their contract and state law, so the deadline may be shorter.
• No surprise billing protection. The No Surprises Act does not cover these products. See Surprise bills.

What next

• Who regulates your plan shows how to find the right agency.
• After a final denial lists what is left when the company says no.
• Student, short-term and other coverage lists every page in this group.