The Health Insurance Risk-Sharing Plan (HIRSP) provides medical and
prescription drug 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.
Program costs are shared by policyholders, health insurance companies
that do business in Wisconsin, and health care providers. During fiscal
year (FY) 2004-05, HIRSP also received $2.2 million in federal funds
designated for high-risk health insurance pools.
HIRSP offers eligible applicants three plans:
The primary plan, plan 1A, is similar to coverage provided by many
private major medical health insurance 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 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, 2005 and 2004.
Financial Status
Beginning with FY 2001-02, DHFS
and HIRSP’s Board of Governors
implemented an accrual-based
funding approach to address an
accounting deficit.
As a result, HIRSP’s accounting
balance, as represented by its
unrestricted net assets, improved to
$6.8 million as of June 30, 2004.
However, the balance decreased
$7.1 million during FY 2004-05,
resulting in a small deficit of
$300,000 as of June 30, 2005.
At least a portion of the decrease
in the balance was expected in
response to the Board’s decision to
apply $3.9 million in accumulated
insurers’ and providers’ balances
toward FY 2004-05 expenses.
However, an unexpectedly large
increase in claims costs contributed
to a larger decrease than expected
and to the small deficit. The deficit
appears to have been addressed
in FY 2005-06.
Enrollment and Claims Costs
Although HIRSP experienced
double-digit enrollment growth
for several years, total enrollment
increased 5.4 percent during
FY 2004-05.
There were 19,385 policyholders as
of June 30, 2005. During FY 2005-06,
enrollment decreased slightly to
reach 18,650 on June 30, 2006.
In contrast to moderating enrollment,
claims costs continue to increase
significantly. Net of health care
providers’ contributions, claims
costs increased $76.3 million over
the past five years.
Claims costs have been affected by
increases in prescription drug and
medical costs that are similar to
those experienced by other payers.
HIRSP’s contracted actuary cites
increased utilization of services
by policyholders as another
contributing factor.
Changes in Costs and Contributions
Health care providers help to fund
HIRSP through reduced reimbursements
for billed services. Their share
of program funding is calculated by
subtracting “allowable charges,”
which are generally a percentage of
Medicaid reimbursement rates, from
“usual and customary” charges.
Usual and customary charges are
intended to reflect the range of fees
that most health care providers in
a given area charge for a given
procedure. They are common to the
health insurance industry and are
established annually by most insurers
as discounts to billed charges.
HIRSP, however, maintained the
same discount—approximately
20 percent, in aggregate, of billed
charges—from 1998 through 2004.
Because providers’ billing rates
increased during that period, maintaining
the “usual and customary”
discount caused HIRSP’s claims
costs and provider contributions to
increase more than was expected.
In response, DHFS and HIRSP’s
Board of Governors increased
the discounts applied to claims
from January 1, 2004 through
June 30, 2005 to approximately
30 percent of billed charges, which
DHFS and the Board believed was
more representative of industry
averages. As a result, shared
program costs for the 18-month
period decreased by $25.5 million.
After additional research and
analysis, the discount rates were
adjusted to 28.5 percent effective
July 1, 2005. However, this change
was mistakenly not implemented. As
a result, program costs and provider
contributions were calculated at an
estimated $3.6 million less than they
should have been for the first nine
months of FY 2005-06.
If uncorrected, the miscalculation
would have materially misstated
the financial statements. After we
informed DHFS of the oversight,
DHFS requested that the plan
administrator implement the
28.5 percent discount rate and
make the necessary adjustments
to ensure program costs and
provider contributions were properly
calculated in FY 2005-06.
DHFS also requested that HIRSP’s
contracted actuary assess the effect of
the miscalculation on the FY 2006-07
budget projections. HIRSP’s Board
of Governors subsequently voted to
amend the original budget and to
increase provider payment rates
for FY 2006-07 by 4.5 percent.
Program Changes
2005 Wisconsin Act 74 created
the HIRSP Authority, which
assumed responsibility for HIRSP
on July 1, 2006. The HIRSP
Authority is not a state agency
and is not subject to the State’s
budgeting process, but some level
of public accountability is retained
through open records and open
meetings requirements. The Audit
Bureau also is required to continue
auditing HIRSP on an annual basis.
Act 74 also made several other
significant changes to HIRSP,
including:
simplifying the complex funding formula;
providing the HIRSP Authority further flexibility in establishing plan design;
tightening eligibility requirements; and
establishing tax credits for the insurers that help to fund HIRSP.