Federal and State Policy Toward Association Health Plans in Oregon

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Research shows that some small employers may be missing out on important consumer protections under the Affordable Care Act (ACA) by purchasing health insurance through an association health plan.

The Issue:

To understand the effect of the ACA on the association health plan (AHP) market, the authors examined Oregon as a case study since the state had a sizable AHP market prior to health reform. They write that Oregon insurers claim association health plans fall under the Employee Retirement Income Security Act and are thus, not required to meet the ACA protections for the small-group market.


  • Exposing consumers to plans that may not cover the essential health benefits mandated by the ACA

  • Consumers could be discriminated against based on age, gender or health status

  • Despite these risks to consumers, association health plans have the potential to grow their market share in Oregon


The report illustrates that AHPs allow Oregon insurers to sidestep key consumer protections that otherwise apply to coverage sold in the small-group market under the ACA.

About the Grantee:

The Center on Health Insurance Reforms at Georgetown University’s Health Policy Institute is a nonpartisan, expert team of faculty and staff dedicated to conducting research on the complex and developing relationship between state and federal oversight of the health insurance marketplace.