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On March 21 the 15-member Consumer Operated and Oriented Plan (CO-OP) program Advisory Board submitted recommendations to HHS about the circumstances that would warrant the development of a nonprofit, member-run co-operative health plan (PPACA Section 1322). Among its suggestions:

• HHS should develop flexible criteria that recognize the diversity of market conditions around the country and enable differing models of CO-OPs created and supported by different types of sponsors to develop.
• In awarding loans and grants, preference should be given to applicants with a strong local network and model of integrated care over an application that includes a state-wide network with little emphasis on care coordination.
• HHS should make every effort to help a CO-OP succeed by providing or arranging for needed technical and management support as well as additional funding.

Note: Per Section 1322, $6 billion in loans are available to capitalize eligible prospective CO-OPs: start-up loans to be repaid in five years and grants to meet state insurance solvency/reserve requirements to be repaid in 15 years. Draft regulations for this program are expected later this spring.