The Health Insurance Risk-Sharing Plan (HIRSP) was established in
1980 to provide medical insurance for individuals who cannot obtain
coverage in the private market because of the severity of their health
conditions. In the late 1990s, it was also designated as Wisconsin’s plan
to meet federal Health Insurance Portability and Accountability Act
regulations and to provide health insurance to people who lose
employer-sponsored group health insurance and meet other specified
criteria.
HIRSP is funded through policyholder premiums; financial assessments
on health insurance companies that do business in Wisconsin; reduced
reimbursements to health care providers; and, until recently, general
purpose revenue (GPR). As of June 30, 2003,17,017 policyholders were
enrolled in HIRSP. HIRSP offers eligible applicants three plans:
The primary plan, plan 1A, is similar to coverage provided by many
private major medical plans.
The alternative plan, plan 1B, offers the same coverage as plan 1A
but at lower premium rates, and it requires policyholders to pay a
higher deductible before HIRSP begins paying claims.
An additional plan, plan 2, is available to Wisconsin residents under
the age of 65 who participate in the federal Medicare program
because of a disability.
At the request of the Department of Health and Family Services
(DHFS), we completed a financial audit of HIRSP. Our audit report
contains our unqualified opinion on HIRSP’s financial statements and
related notes for the fiscal years ending June 30, 2002 and 2001.
Financial Status of the Plan
Since we began auditing HIRSP’s
financial statements in 1998, we
recommended that HIRSP be
funded on an accrual basis, rather
than the cash-based approach
used at the time.
A cash-based funding approach
takes into account estimated cash
disbursements. An accrual basis
takes into account the full costs
associated with events that occur
during a plan year, including
actuarial cost estimates for claims
incurred that may not be filed
until after the plan year.
HIRSP previously used a cashbased
funding approach that
contributed to an accounting
deficit because it did not factor
in all claims liabilities. As a result,
HIRSP’s accounting deficit of
$8.2 million as of June 30, 2001,
represented the estimated additional
cash HIRSP would eventually
need to make payment on
its liabilities.
DHFS and HIRSP’s Board of
Governors decided to implement
an accrual-based approach to
funding HIRSP beginning with
FY 2001-02. The change to an
accrual-based approach required
funding to eliminate the accounting
deficit that had accumulated
under the cash-based approach, in
addition to funding HIRSP’s newly
incurred costs on an accrual basis.
As a result of increasing program
costs and the funding change,
policyholder premiums and insurer
assessments increased significantly
during fiscal year (FY) 2001-02. Total
premiums increased 29.3 percent,
while insurer assessments almost
doubled, from $9.9 million in
FY 2000-01 to $19.6 million in
FY 2001-02.
The increased revenues that resulted
from increases in premiums
and insurer assessments contributed
to a $2.7 million reduction
in HIRSP’s accounting deficit,
which was $5.5 million as of
June 30, 2002. Based on preliminary
unaudited financial statements,
the deficit was less than
$1.0 million as of June 30, 2003.
Increasing Enrollment and Claims Costs
Increasing enrollment and claims
costs present continuing challenges
to the management and funding of
HIRSP. Policyholder enrollment
increased 16.9 percent during
FY 2002-03, to 17,017 policyholders
as of June 30, 2003, and continues
to increase.
Although growth has begun to level
off for two of the plans in recent
years, enrollment in plan 1B has
continued to increase steadily.
While a variety of factors may have
contributed to interest in plan 1B,
its lower premiums in comparison
to plan 1A have made it popular.
Like enrollment levels, HIRSP’s
claims costs are also increasing. Net
of health care providers’ discounts,
the increase was 48.7 percent, or
$17.7 million, in FY 2000-01, and
24.1 percent, or $13.1 million, in
FY 2001-02. Based on unaudited
data, claims costs increased
27.8 percent, or $18.7 million, in
FY 2002-03.
A large portion of these increases can
be explained by the enrollment
increases, although they are also
affected by increases in medical costs
similar to those experienced by others
in the health insurance industry. For
example, the average cost per HIRSP
policyholder, net of provider discounts,
increased 12.5 percent, from $4,824 in
FY 2000-01 to $5,428 in FY 2001-02.
Enrollment and cost trends are also
increasing required funding levels.
If these trends continue, pressures
likely will increase to control the
costs borne by HIRSP’s funding
parties and to evaluate the fairness
and effectiveness of the current
funding structure.
Budget Provisions
Beginning in FY 1997-98, the
Legislature provided GPR funding
to offset program costs, in addition
to GPR funding for premium and
deductible subsidies available for
low-income policyholders that had
been in place for several years.
GPR support for HIRSP during
the 2001-03 biennium totaled
$21.0 million.
Under 2003 Wisconsin Act 33, the
2003-05 Biennial Budget Act, all
GPR support for HIRSP is eliminated,
effective FY 2003-04. The
other funding parties are now
required to pay for costs previously
funded through GPR.
Act 33 also eliminated the requirement
that the HIRSP plan administrator
be the Medicaid fiscal agent,
and instead authorizes DHFS to
select the HIRSP plan administrator
through a competitive bidding
process. HIRSP’s Medicaid fiscal
agent has been the administrator
since 1998. DHFS is currently
developing a request for vendor
proposals, with the intent of selecting
and contracting with a vendor
to administer HIRSP beginning in
FY 2004-05.
Fiscal Management Issues
DHFS has improved the system for
pharmacy claims, which were
$23.1 million during FY 2001-02
and $32.4 million during FY 2002-03,
by using a pharmacy benefit management
company beginning in
FY 2001-02. However, oversight of
pharmacy claims could be further
improved with periodic reviews of
the controls put in place by the
pharmacy benefit management
company.
Claims processing organizations
and other entities that provide
similar services to several organizations
often obtain special independent
external reviews of their
controls to fulfill the needs of user
organizations and their auditors.
These reviews, which are commonly
referred to as “SAS 70” service
organization audits, provide an
in-depth audit of a service
organization’s control activities.
Although HIRSP’s plan administrator
regularly obtains a SAS 70
audit, the pharmacy benefit management
company does not. In
response to recommendations we
made orally during this audit,
DHFS is considering pursuing a
SAS 70 audit or alternative steps to
provide independent reviews of
controls over pharmacy claims.
DHFS has also taken steps to address
two areas of concern identified
during our FY 2000-01 audit.
First, we found that inadequate
procedures and communication
regarding claims data and the
actuarial process led to an estimate
of actuarial loss liabilities that was
materially in error and required an
adjustment to HIRSP’s financial
statements. In response, procedures
were revised, and the Board of
Governor’s Financial Oversight
Committee took responsibility to
review the loss liability estimates.
The estimates for the FY 2001-02
financial statements were materially
correct.
The second area of concern in our
prior audit was problems with
plan administrator fees, which
totaled $3.2 million in FY 2001-02.
In response, DHFS implemented
a streamlined fee structure to
simplify the billing process and
make it easier to monitor administrative
invoices. We noted no
problems during our current audit.