Posts Tagged ‘Health Care Reform’

CO-OP Program Update

August 10, 2011

The Affordable Care Act established the Consumer Operated & Oriented Plan (“CO-OP”) Program.  The Program makes federal loans available to new consumer run, non-profit private health insurers in an effort to increase competition in the health insurance marketplace.  Last month HHS issued proposed rules and a funding announcement outlining the requirements of CO-OPS and the loan program.  Today HHS held a conference call to answer questions from parties interested in creating a CO-OP.  Those interested in forming a CO-OP should note the following from today’s call:

  • CO-OPs that receive federal funding cannot restrict members to a specific industry but must accept any willing applicant (for example, a trade association could not establish a CO-OP and restrict membership to association members);
  • Members of the CO-OP (who ultimately control the CO-OP) are the individuals covered by the insurance (not the employers offering the insurance);
  • CO-OPs must offer insurance in the individual market and cannot limit their business to the group market;
  • Start up costs incurred prior to the loan award are not reimbursable from loan funds; however, up to $100,000 in costs directly related to establishing the business plan and feasibility study required by the loan application are reimbursable if a loan is ultimately awarded;
  • Prior to submitting an application, the applicant must have initiated discussion regarding licensure with the applicant’s state Insurance Department but does not need to be licensed at the time the application is submitted; and
  • The first application deadline for CO-OP funding is October 17, 2011.  While applications will continue to be accepted through December 31, 2012, funding is limited and could be exhausted prior to that time.

 The proposed rule and funding announcement can be accessed at    Interested parties who have questions about the Program can submit them to   Responses will be provided in the form of Frequently Asked Questions on CMS’ website.


Welcome to the Davis Brown Health Care Reform Blog

July 22, 2011

Susan J. Freed

I am a health law and employee benefits attorney at the Davis Brown Law Firm in Des Moines, Iowa.  Our clients include private and governmental employers, self-insured health plans, multiple employer welfare arrangements, agents and brokers and a wide variety of health care providers.

Over the past 16 months we have assisted clients with implementing various portions of the Patient Protection & Affordable Care Act (the “Affordable Care Act”), the federal health care reform legislation passed in March 2010.  Because the act’s requirements are continually evolving and implementation is spread over many years, we are frequently updating clients on new developments and implementation issues.

We’ve developed this blog as a way to provide clients with the most up-to-date information—including updates on the federal government’s implementation of the Affordable Care Act, new regulations, recently issued guidance and enforcement updates.  The blog will also comment on any issues specific to the State of Iowa.

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