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 (HIPAA) regulations and to provide health insurance to people
who lose employer-sponsored group health insurance and meet other
specified criteria.
HIRSP is primarily 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 February 29, 2004,
17,669 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 because policyholders 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 our sixth 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, 2003 and 2002.
Financial Status of the Plan
Because of its cash-based funding
approach, HIRSP had an accounting
deficit of $8.2 million as of
June 30, 2001. This deficit represented
estimated additional cash
that HIRSP would eventually need
to pay covered medical expenses
that had been incurred but not
paid before this date.
DHFS and HIRSP’s Board of
Governors implemented an
accrual-based funding approach
beginning with fiscal year
(FY) 2001-02. An accrual basis
takes into account the full costs
associated with events that occur
during a plan year, including
actuarial cost estimates for incurred
claims that may not be filed
until after the plan year.
The change to an accrual-based
approach required funding to
eliminate the accounting deficit
that had accumulated under the
cash-based approach, as well as
funding for newly incurred costs
accounted for on an accrual basis.
As a result of increasing enrollment
and program costs, as well as the
change in the funding approach,
policyholder premiums and insurer
assessments increased significantly
in FY 2001-02 and FY 2002-03.
Total premium revenue almost
doubled, while insurer assessments
increased 162.7 percent.
The increased revenues that
resulted from increases in premiums
and insurer assessments
contributed to a $5.1 million
reduction in HIRSP’s accounting
deficit, which was $0.9 million as
of June 30, 2003.
Statutes require policyholders to
fund 60 percent of HIRSP’s costs
and establish a floor for policyholder
premiums of at least 150 percent
of standard risk rates through
July 29, 2002, and 140 percent of
standard risk rates as of July 30, 2002.
Statutes also require a separate
accounting of premiums received in
excess of the amount needed to
cover policyholders’ 60 percent
share of HIRSP’s costs.
Because the statutory floor for
premium rates has typically been
greater than the premiums needed
to fund 60 percent of HIRSP’s costs,
and because actual claims costs
were less than the costs assumed in
HIRSP’s FY 2002-03 budget, the
excess policyholder premium
account balance increased significantly
during FY 2002-03, from
$3.0 million to $10.4 million as of
June 30, 2003.
The use of these funds is statutorily
restricted for these purposes:
to reduce policyholder premiums
to the statutory minimum
when the policyholders’ share
of costs would otherwise
require a premium increase;
for other needs of eligible
persons, with the approval of
the Board of Governors; or
for distribution to eligible
persons.
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. However, enrollment
experience during the first
eight months of FY 2003-04 suggests
that enrollment growth may
be beginning to slow: enrollment
increased by 3.8 percent, to 17,669
as of February 29, 2004.
Enrollment in plans 1A and 2
began to level off in FY 2002-03,
although enrollment in plan 1B
continued to increase steadily.
Further, an increasing number of
participants have shifted from
plan 1A to plan 1B in recent years.
The greatest shift occurred in 2003,
when 713 participants changed
from plan 1A to plan 1B.
Net of health care providers’
discounts, claims costs increased
171.1 percent, or $54.2 million, over
the last five years. A large portion of
these increases can be explained by
the enrollment increases, although
HIRSP claims costs also have been
affected by medical cost increases
similar to those experienced by others
in the health insurance industry.
Legislative Activity
The Legislature began providing GPR
funding to offset program costs in
FY 1997-98. At that time, GPR funding
to subsidize premiums and
deductibles for low-income policyholders
had been in place for several
years. During the 2001-03 biennium,
GPR support for HIRSP totaled
$21.0 million.
Under 2003 Wisconsin Act 33, the
2003-05 Biennial Budget Act, all
GPR support for HIRSP was eliminated
beginning in FY 2003-04.
The other funding parties—policyholders,
insurers, and health care
providers—are now required to
pay for costs that had previously
been funded through GPR.
Act 33 also authorizes DHFS to
select the HIRSP plan administrator
through a competitive procurement
process. Since 1998, statutes had
required that the Medicaid fiscal
agent serve as HIRSP’s administrator.
DHFS is currently conducting a
competitive procurement process
with the intent of selecting and
contracting with a vendor to
administer HIRSP beginning in
January 2005, after a six-month
transition period.
In light of HIRSP’s increasing costs
and the loss of GPR, legislation was
introduced in February 2004 to
expand the funding base to include
drug manufacturers and drug
labelers, which are companies that
repackage prescription drugs for
retail sale.
Under 2003 Senate Bill 466, which
was not enacted, each manufacturer
or labeler that provided
prescription drugs under HIRSP
would have been required to pay
an annual assessment based on
claims that HIRSP paid for their
drugs in the previous calendar
year. On a per claim basis, the
assessment amount would have
been equal to the rebate amount
the drug manufacturer or labeler
pays for the drug under Medicaid.
At 37.8 percent of net claims paid
during FY 2002-03, prescription
drug claims represent the secondlargest
portion of HIRSP’s claims
costs. HIRSP currently receives
some drug rebates as part of the
agreement with its plan administrator,
including $677,118 during
FY 2002-03.
Technical Statutory Issue
DHFS and HIRSP’s contracted
actuary have identified a technical
statutory issue that will require
legislative action.
Under current statutes, the method
by which HIRSP’s funding formula
applies deductible and drug coinsurance
subsidies for low-income
policyholders results in policyholders
being over-credited for subsidies
they did not fund, and a
related portion of costs not being
allocated to any funding party.
DHFS and the Board of Governors
decided in 2001 that $1.5 million of
unallocated costs associated with
the deductible subsidy credit
would be paid by policyholders,
insurers, and health care providers
based on the statutory funding
split used for HIRSP costs. These
costs had accumulated during
1998, 1999, and 2000.
In March 2004, the Board’s Financial
Oversight Committee approved
a recommendation to the Board to
reduce the excess policyholder
premium account by the amount of
over-credited deductible subsidies
as of March 31, 2004. The unallocated
balance was $2.1 million as
of February 29, 2004. DHFS and
the Board of Governors plan to
pursue statutory changes to address
this technical issue during the
2005-07 legislative session.