California Policy Perspectives on Association Health Plans

Association health plans (AHPs) are insurance arrangements that allow small businesses, associations, and self-employed workers to organize together to purchase health care coverage, potentially obtaining lower-priced coverage by spreading risk and negotiating on behalf of a larger set of enrollees. Recent federal regulatory changes have expanded the definition of AHPs to reduce the requirements and conditions under which such entities could form, while also bypassing the coverage requirements specified in the Affordable Care Act (ACA). In response, many states have issued regulations that seek to mitigate the effects that AHPs could have on other insurance products and to reinforce the consumer protections that the ACA requires.

California Policy Perspectives on Association Health Plans examines these developments and the current market for AHPs in California, including a related expansion of less-regulated professional employment organization (PEO) insurance products. Interviews with current market participants and observers suggest a potential need for additional oversight of both AHPs and PEOs. Absent such oversight, the spread of coverage products not fully compliant with the consumer protections codified by the ACA may lead to adverse risk selection and undermine the functioning of individual and small group markets both within and outside the Covered California health insurance exchange.

Authors & Contributors

Emma Hoo

Emma Hoo directs several initiatives for the Purchaser Business Group on Health (PBGH) that promote effective health management, provider accountability, consumer engagement, accountable care organizations, and private health insurance exchanges. The overall goal of these initiatives is to empower and encourage consumers to take control of their health care, and ensure that providers are rewarded for delivering efficient and quality care. Emma leads joint purchasing initiatives for California HMO services, as well as retiree coverage and pharmacy benefit management services. Additionally, Emma oversees the assessment of health plan performance through analyzing and reporting health care performance data.

Prior to joining PBGH in 1997, Emma was director of operations for a northern California medical group, with responsibility for contracting, data analysis, and information systems.

Emma received her bachelor of arts in social studies from Harvard University.