GAO-12-62R Pre-Existing Condition Insurance Plan Program

United States Government Accountability Office

Washington, DC 20548 

November 10, 2011 

The Honorable Harry Reid 

Majority Leader 

United States Senate 

The Honorable Max Baucus 

Chairman 

Committee on Finance 

United States Senate 

The Honorable Tom Harkin 

Chairman 

Committee on Health, Education, Labor, and Pensions 

United States Senate 

Subject: Pre-Existing Condition Insurance Plan: Comparison of Implementation and 

Early Enrollment with the Children’s Health Insurance Program

The federal Pre-Existing Condition Insurance Plan (PCIP) was created in 2010 to 

provide access to insurance for individuals previously unable to acquire coverage 

due to pre-existing conditions.1 Eligibility is limited to those who have been 

uninsured for at least 6 months prior to application, thus focusing the program on 

those who have been locked out of the private insurance market. The Patient 

Protection and Affordable Care Act (PPACA), enacted in March 2010, required the 

establishment of the PCIP program. The program will provide coverage through the 

end of 2013, at which point enrollees will be guaranteed access to plans offered in 

the private market. States were given the option to run their own PCIP with federal 

funding or allow the Department of Health and Human Services (HHS) to run the 

program in their state.2

 Early estimates by the Congressional Budget Office (CBO) 

 

1

The PCIP program is modeled after existing state-operated high risk pools (HRP), which provide 

access to coverage and subsidize premiums for those with pre-existing conditions to make them 

more affordable. HRPs existed in 35 states as of September 2011, according to the website of the 

National Association of State Comprehensive Health Insurance Plans, the national organization of 

state-operated HRPs. See http://naschip.org. 

2

Pub. L. No. 111-148, § 1101, 124 Stat. 119, 141 (2010). Twenty-seven states elected to administer a 

PCIP, while 23 states and the District of Columbia opted for HHS to administer their PCIP. By law, 

PCIP premiums must be established at a standard rate for a standard population and may vary only 

by age—by no more than a 4 to 1 ratio—geography, and smoking status. 
2 GAO-12-62R Pre-Existing Condition Insurance Plan Program

suggested that the program could cover an average of 200,000 individuals per year 

with the $5 billion appropriated in PPACA, but that demand would likely be greater.3

In July 2011, we reported on various aspects of the implementation of the PCIP 

program, including initial enrollment and spending trends, program features, and 

federal oversight.4 As part of that work we interviewed PCIP officials from states with 

and without existing high risk pools (HRP) about the steps taken to implement PCIP 

in their states.5

As a new federal program, there is interest both in how the PCIP program has been 

implemented and how its implementation compares to another publicly funded 

insurance program—the Children’s Health Insurance Program (CHIP). CHIP was 

authorized in August 1997 to reduce the number of low-income uninsured children in 

families with incomes too high to qualify for Medicaid.6

 Like Medicaid, CHIP is 

funded jointly by the federal government and the states. CHIP enrollment data are 

provided to HHS quarterly by the states, beginning with the first quarter of fiscal year 

1998. When CHIP was passed, the CBO estimated that the program would provide 

coverage to about 2.3 million children per year after 1999. 

You asked us to compare early program implementation and enrollment across 

PCIP and CHIP. In this report, we examine: (1) how long it took to implement PCIP 

and CHIP in all states; (2) initial enrollment trends for PCIP and CHIP; and (3) any 

differences in implementing PCIP, and trends in enrollment, between states that had 

high risk pools prior to the enactment of PPACA, and those that did not. 

To address these objectives, we relied primarily on our July 2011 report examining 

implementation of the PCIP program and a report prepared under contract with the 

Centers for Medicare and Medicaid Services (CMS) within HHS examining CHIP 

enrollment patterns.7 To compare how long it took to implement PCIP and CHIP, we 

identified the date enrollment began in each state and determined the number of 

months until the programs were active in all 50 states and the District of Columbia.8,9

 

3

CBO estimated in June 2010 that if funding were not limited to $5 billion, enrollment could reach 

700,000 by the end of 2013 at a cost of up to $15 billion. See Congressional Budget Office, letter to 

the Honorable Michael Enzi regarding the high risk insurance pools included in PPACA (June 21, 

2010). 

4

See GAO, Pre-Existing Condition Insurance Plans: Program Features, Early Enrollment and 

Spending Trends, and Federal Oversight Activities, GAO-11-662 (Washington, D.C.: July 27, 2011).

5

We interviewed officials in eight states, including four with existing HRPs (Alaska, Connecticut, 

Illinois, and North Carolina) and four without (Maine, Michigan, Ohio, and Pennsylvania). 

6

Balanced Budget Act of 1997 (BBA), Pub. L. No. 105-33, § 4901(a), 111 Stat. 251, 552. The act 

appropriated funds in 1-year increments over a period of 10 fiscal years (1998-2007), a total of 

approximately $40 billion for allotment to states to carry out the CHIP program. 

7

See GAO-11-662 and “SCHIP’s Steady Enrollment Growth Continues: Final Report, May 2003,” 

Mathematica Policy Research, Inc., Cambridge, Mass., a report prepared under contract with CMS. 

PCIP data were originally provided by CMS. CHIP data reported by Mathematica were obtained from 

CMS’s CHIP Statistical Enrollment Data System. 

8

The BBA established the CHIP program upon enactment, while PPACA required HHS to establish 

the PCIP program within 90 days of enactment. To facilitate our comparison of the implementation 

time frames of both programs, we measured the number of months from the date of enactment until 

the programs began enrolling individuals. 

9

We generally refer to the 50 states and the District of Columbia as “51 states.” 
3 GAO-12-62R Pre-Existing Condition Insurance Plan Program

To compare initial enrollment trends, we compared quarterly enrollment data for the 

first year of each program. Additionally, we interviewed officials from CMS to identify 

key factors to consider when comparing implementation and enrollment across the 

two programs. To compare any differences in implementing PCIP, and trends in 

enrollment, in states that did and did not have an existing HRP, we reviewed 

interviews conducted with state PCIP officials for our July 2011 report and analyzed 

implementation dates and enrollment data. 

To assess the reliability of PCIP and CHIP implementation and enrollment data, we 

discussed with CMS officials the steps taken to ensure data accuracy and 

completeness and reviewed related documentation. We determined the data were 

sufficiently reliable for our purposes. We conducted this performance audit from 

August 2011 through October 2011 in accordance with generally accepted 

government auditing standards. Those standards require that we plan and perform 

the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe that the 

evidence obtained provides a reasonable basis for our findings and conclusions 

based on our audit objectives. 

Results in Brief 

We found that the PCIP program was implemented in all states within 7 months, 

while the CHIP program rolled out over a period of nearly 3 years.10 In comparing the 

two programs, there are differences to consider that may account for the difference 

in implementation times, such as the different statutory requirements regarding 

implementation time frames, the mandatory versus voluntary nature of the two 

programs, the relative complexity of program requirements, the number of design 

decisions to be made, and different funding sources. 

Enrollment in the PCIP and CHIP programs was slow to start but increased steadily 

over the first year, ending with more than 27,000 and 705,000 enrollees, 

respectively. Changes to PCIP eligibility criteria and premium rates intended to help 

expand enrollment were made immediately after the first year of the program. 

PCIP implementation took slightly less time, on average, in states that had an 

existing HRP compared to those that did not—5.5 months compared to 6.1 months. 

Enrollment, however, was lower relative to the uninsured population in each state 

with an existing HRP—3.7 individuals per 10,000 uninsured, compared to 5.5 among 

states without an HRP. 

In reviewing a draft of this report, HHS provided technical comments, which we 

incorporated as appropriate. 

 

10We use “implemented” to indicate that the state was actively enrolling individuals in a program, or, 

in the case of one state’s PCIP plan, had operationalized the program but had not yet enrolled any 

applicants. 
4 GAO-12-62R Pre-Existing Condition Insurance Plan Program

PCIP Was Implemented within 7 months, while CHIP Rolled Out More Slowly 

Within months the PCIP program was implemented in all states. The first PCIP plans 

(in New Hampshire and South Dakota) began enrolling individuals in July 2010, 

4 months after PPACA was enacted. Plans were established in most states by 

August, and in all 51 states by October 2010, just 7 months after passage. CHIP 

was implemented more slowly. By the first CHIP quarterly enrollment report ending 

December 1997—4 months after enactment of the Balanced Budget Act of 1997—8 

states had begun enrollment. By the end of fiscal year 1998, 31 states had 

implemented their programs. An additional 17 states began enrolling during fiscal 

year 1999, and all states had implemented their programs by the end of fiscal year 

2000, nearly 3 years after enactment. See figure 1, and for more details see 

enclosure I. 

Figure 1: Number of States Implementing PCIP and CHIP by Months Since Enactment 

0

5

10

15

20

25

30

35

40

45

50

987654321 10 11 141312 1615 1817 19 252423222120 26 2827 29 3130 32 3433 35 36

Months since enactment

Source: GAO analysis of data from CMS (PCIP data) and Mathematica Policy Research (CHIP data).

CHIP cumulative states

PCIP cumulative states

Number of states implementing PCIP and CHIP

51

Note: For the PCIP program, enrollment in state-run programs began with 2 states in July 2010 (4 months after enactment), 9 

states in August, 12 states in September, and 4 states in October 2010. Among states that opted for HHS to run the program, 

21 began in August 2010, 2 in September, and 1 in October 2010. 

In comparing the pace of implementation between PCIP and CHIP, there are certain 

key differences to consider. First, PCIP was a mandatory program statutorily 

required to be implemented within a specified time frame,11 while the implementation 

of CHIP was conditioned on the voluntary participation of states12 and without a 

specified time frame. Second, the programs varied in terms of their relative 

complexity. The steps taken to implement the PCIP program were relatively 

straightforward—for example, PCIP plans were required to determine the eligibility of 

applicants, provide certain minimum benefits, and calculate premiums based on the 

standard market rate. In the process of establishing CHIP, states faced similar and 

 

11Specifically, PPACA required HHS to establish the PCIP program within 90 days of enactment. 

12BBA conditioned state participation in the CHIP program on submission of a state child health plan 

meeting applicable requirements, subject to HHS approval. 
5 GAO-12-62R Pre-Existing Condition Insurance Plan Program

some additional design decisions—for example, whether to implement CHIP by 

expanding their Medicaid programs, creating a stand-alone CHIP program, or both; 

eligibility; scope of benefits; and cost-sharing, among others.13 Third, the two 

programs are funded differently. PCIP plans are funded through the $5 billion 

appropriation and premiums collected from enrollees, whereas states were required 

to fund a significant share of CHIP spending, adding weight to the effect of their 

timing and design choices. Further, for states that opted to let HHS administer the 

PCIP in their state, the use of a single national carrier may have provided 

efficiencies resulting in earlier implementation. CHIP, in contrast, was separately 

administered by each state. 

Enrollment in Both Programs Was Slow to Start, but Increased during First 

Year 

The initial enrollment levels for both PCIP and CHIP were significantly below CBO 

projections. During its first quarter, PCIP saw a modest enrollment of less than 3,000 

individuals. Enrollment had increased to more than 11,000 by the second quarter 

and to more than 27,000 by the end of the first year.14 CHIP, a much larger-scale 

program, ended its first quarter with more than 47,000 enrollees. Enrollment more 

than doubled by the second quarter and rose to more than 705,000 across 31 states 

by the end of the first year.15 See table 1 for a quarterly breakdown of total 

enrollment and number of states with active programs and enclosure II for year-end 

enrollment by state. 

 

13For more details on states’ initial approach to CHIP implementation, see GAO, Children’s Health 

Insurance Program: State Implementation Approaches are Evolving, GAO/HEHS-99-65 (Washington, 

D.C.: May 14, 1999). See also GAO, Children’s Health Insurance: States’ SCHIP Enrollment and 

Spending Experiences and Considerations for Reauthorization, GAO-07-558T (Washington, D.C.: 

Mar. 1, 2007). 

14PCIP enrollment as of August 31, 2011, the most recent data available at the time of this report, 

was 33,958. 

15CHIP continued to grow steadily for more than a decade, eventually exceeding CBO’s projection of 

about 2.3 million enrollees per year during its third year of operation. By the final quarter of fiscal year 

2000, all 51 states had implemented CHIP with a total enrollment of nearly 2.7 million. By fiscal year 

2010, CMS reported CHIP enrollment had reached nearly 7.7 million. 
6 GAO-12-62R Pre-Existing Condition Insurance Plan Program

Table 1: First-year Quarterly Enrollment for PCIP & CHIP 

First quarter Second quarter Third quarter Fourth quarter 

PCIP 

Total enrollmenta 2,777 11,377 18,351 27,416 

Time period July – Sept. 2010 Oct. – Dec. 2010 Jan. - March 2011 April - June 2011 

Number of statesb 46 51 51 51 

CHIP 

Total enrollmenta 47,082 106,617 408,160 705,004 

Time period Oct. – Dec. 1997 Jan. - March 1998 April - June 1998 July – Sept. 1998 

Number of statesb 8 12 18 31 

Source: GAO analysis of data from CMS (PCIP data) and Mathematica Policy Research (CHIP data). 

a

Enrollment totals for PCIP represent the number of individuals enrolled in the final month of each quarter. Enrollment totals for 

CHIP represent the number of children ever enrolled in CHIP during the quarter, including those who may have disenrolled 

before the end of the quarter. 

b

Number of states represents those states that were actively accepting enrollment applications. 

In comparing enrollment growth between the two programs, there are certain key 

differences to consider. To avoid covering applicants who had access to other 

sources of coverage, the PCIP statute required that eligible applicants be uninsured 

for at least 6 months—the most common factor explaining lower than expected 

enrollment cited by the state PCIP officials we interviewed for our prior PCIP report. 

Such uninsured periods prior to eligibility were less of an issue with CHIP. While 

CHIP was similarly intended for children without access to other sources of 

coverage, the statute did not prescribe any particular method to exclude them, and 

only some states did so during the first year of implementation by requiring 

applicants to go without insurance coverage for a specified period. Additionally, state 

PCIP officials told us they considered the cost of premiums—more than $400 per 

month on average for a 50-year-old person—to be a barrier to enrollment. In 

contrast, many states did not charge any CHIP premiums, and among those states 

that did, premiums were significantly lower compared to PCIP. 

Enrollment data for the PCIP program do not reflect recent changes made by HHS 

to increase enrollment, including relaxing eligibility standards, lowering premiums, 

and increasing its outreach efforts.16 Specifically, HHS decided to allow, beginning 

July 2011, a letter from a provider attesting to an individual’s pre-existing condition 

as acceptable documentation for enrollment in the federal PCIP.17 Also beginning in 

July, HHS reduced premiums in 18 federally run PCIP states, ranging from 2 percent 

in 1 state to 40 percent in 6 states. The department increased its outreach efforts in 

2011 to include PCIP marketing at more than 100 events and conferences, made 

arrangements with major insurance carriers to include information about the PCIP 

program in denial letters, and established referral fees for agents and brokers who 

successfully enroll individuals in a PCIP plan. 

 

16See “HHS to Reduce Premiums, Make it Easier for Americans with Pre-Existing Conditions to Get 

Health Insurance,” HHS news release (May 31, 2011), accessed June 1, 2011, 

www.hhs.gov/news/press/2011pres/05/20110531b.html. 

17HHS had previously only accepted a denial letter from an insurance carrier or an offer of insurance 

but with a rider excluding coverage for the pre-existing condition as evidence of an applicant’s preexisting condition. 
7 GAO-12-62R Pre-Existing Condition Insurance Plan Program

States That Had Existing HRPs Implemented PCIPs Somewhat Faster than 

Those That Did Not, but Their Enrollment Was Lower 

Among the 27 states that administered their own PCIP, enrollment generally began 

somewhat sooner in states that had an existing HRP. The difference in 

implementation time was small, however—an average of 5.5 months after 

enactment for states with an existing HRP compared to 6.1 months for those states 

without.18 States with existing HRPs may have benefited from their familiarity with a 

similar risk pool program. The states we interviewed in preparing our prior report that 

had an existing HRP—Alaska, Connecticut, Illinois, and North Carolina—all cited 

examples of building upon those programs when implementing PCIP. For example, 

in Alaska, the same nonprofit organization that administers its HRP was also 

selected by the state to run its PCIP, making use of the same provider network, 

pharmacy benefits manager, and disease management organization. Connecticut 

chose the same third-party administrator to handle enrollment and premium 

collection that runs its existing HRP and its health insurance program for uninsured 

adults. Although Illinois runs its PCIP separately from its existing HRP, the state 

Department of Insurance entered into an interdepartmental agreement with the 

board that oversees its HRP to use some of its expertise in advising the PCIP. 

Further, North Carolina, which had launched its HRP only 16 months before HHS 

solicited states’ interest in administering their own PCIP, similarly decided to run its 

own program, governed by the same board that oversees its HRP. 

While states with existing HRPs generally implemented PCIP somewhat sooner, 

their enrollment tended to be lower than PCIP enrollment in states that did not have 

an existing HRP. As we reported in July 2011, compared to the size of the uninsured 

population in each state, PCIP enrollment among states with an existing HRP was 

about 3.7 individuals per 10,000 uninsured, compared to 5.5 among states without 

an HRP. As we noted then, the availability of state-supported health insurance 

programs, such as existing HRPs, may have resulted in lower than expected PCIP 

enrollment in some states. See enclosure III for states’ status regarding an existing 

HRP and whether their PCIP was state or federally run. 

Agency Comments 

HHS provided written comments on a draft of this report (see enc. IV). In its 

comments, HHS reiterated the general purpose of the PCIP and CHIP programs. 

HHS also provided technical comments, which we incorporated as appropriate. 

– – – – – 

As agreed with your offices, unless you publicly announce its contents earlier, we 

plan no further distribution of this report until 30 days from its issue date. At that 

time, we will send copies of this report to the Secretary of HHS and interested 

congressional committees. The report will also be available at no charge on GAO’s 

Web site at http://www.gao.gov. 

 

18Of the 27 states that administered their own PCIPs, 20 had an existing HRP. 
8 GAO-12-62R Pre-Existing Condition Insurance Plan Program

If you or your staff members have any questions about this report, please contact 

me at (202) 512-7114 or dickenj@gao.gov. Contact points for our Offices of 

Congressional Relations and Public Affairs may be found on the last page of this 

report. GAO staff members who made key contributions to this report are Randy 

DiRosa, Assistant Director; George Bogart; Drew Long; and Perry Parsons. 

John E. Dicken 

Director, Health Care 

Enclosures – 4 
Enclosure I 

9 GAO-12-62R Pre-Existing Condition Insurance Plan Program

Implementation Schedules for PCIP and CHIP 

The following tables show for both the Pre-Existing Condition Insurance Plan (PCIP) 

program and the Children’s Health Insurance Program (CHIP), the month each 

state’s programs began enrolling individuals, the number of months after enactment 

of the law creating the program until enrollment began, and the cumulative number 

of states with active programs. 

Table 2: PCIP Implementation 

Month PCIP 

enrollment began 

Months since 

enactmenta Number of 

active states States 

July 2010 4 2 New Hampshire, South Dakota 

August 2010 5 32 Alabama, Arizona, Delaware, Florida, Georgia, 

Hawaii, Idaho, Indiana, Kansas, Kentucky, 

Louisiana, Maine, Massachusetts, Minnesota, 

Mississippi, Missouri, Montana, Nebraska, Nevada, 

New Jersey, New Mexico, North Carolina, North 

Dakota, Oregon, South Carolina, Tennessee, Texas, 

Virginia, Wisconsin, Wyoming 

September 2010 6 46 Alaska, Arkansas, Colorado, Connecticut, Illinois, 

Iowa, Maryland, Ohio, Oklahoma, Rhode Island, 

Utah, Vermont, Washington, West Virginia 

October 2010 7 51 California, District of Columbia, Michigan, New York, 

Pennsylvania 

Source: GAO analysis of data from CMS. 

a

Legislation requiring the establishment of the PCIP program was enacted in March 2010. 
Enclosure I 

10 GAO-12-62R Pre-Existing Condition Insurance Plan Program

Table 3: CHIP Implementation 

Month CHIP 

enrollment began 

Months since 

enactmenta Number of 

active states States 

October 1997 2 7 Connecticut, Idaho, Indiana,b Massachusetts, 

Rhode Island, South Carolina,b

 Tennessee 

December 1997 4 8 Oklahoma 

January 1998 5 10 Illinois, Ohio 

February 1998 6 12 Alabama, New Jersey 

March 1998 7 13 California 

April 1998 8 17 Colorado, Florida, Michigan, New York 

May 1998 9 19 New Hampshire, Pennsylvania 

July 1998 11 30 Iowa, Kentucky, Maine, Maryland, Mississippi, 

Missouri, Nebraska, Oregon, South Dakota, Texas, 

West Virginia 

August 1998 12 31 Utah 

October 1998 14 39 Arkansas, District of Columbia, Minnesota,c

Nevada, North Carolina, North Dakota, Vermont, 

Virginia 

November 1998 15 42 Arizona, Georgia, Louisiana 

January 1999 17 44 Kansas, Montana 

February 1999 18 45 Delaware 

March 1999 19 47 Alaska, New Mexico 

April 1999 20 48 Wisconsin 

December 1999 28 49 Wyoming 

February 2000 30 50 Washington 

July 2000 35 51 Hawaii 

Source: GAO analysis of data from Mathematica Policy Research. 

a

Legislation establishing CHIP was enacted in August 1997. 

b

The source for states’ CHIP implementation date (Mathematica) indicates a start date earlier than October 1997 for Indiana 

and South Carolina, but according to CMS officials this may have referred to the date those states began taking applications, 

as CHIP funding was not available to states until October 1997. 

c

The start date provided by Mathematica for Minnesota was September 30, 1998; however, enrollment was not reported until 

the following quarter. 
Enclosure II 

11 GAO-12-62R Pre-Existing Condition Insurance Plan Program

First-Year Enrollment in PCIP and CHIP, by State 

State PCIP enrollment CHIP enrollment 

Alabama 118 8,106 

Alaska 38 - 

Arizona 639 - 

Arkansas 254 - 

California 2,659 18,291 

Colorado 807 10,377 

Connecticut 57 5,952 

Delaware 73 - 

District of Columbia 30 - 

Florida 1,201 51,664 

Georgia 822 - 

Hawaii 45 - 

Idaho 79 4,339 

Illinois 1,491 22,899 

Indiana 273 20,551 

Iowa 161 4,798 

Kansas 216 - 

Kentucky 140 5,779 

Louisiana 166 - 

Maine 18 3,204 

Maryland 430 27,880 

Massachusetts 1 17,448 

Michigan 339 5,224 

Minnesota 66 - 

Mississippi 105 5,477 

Missouri 433 10,809 

Montana 236 - 

Nebraska 79 2,115 

Nevada 222 - 

New Hampshire 183 71 

New Jersey 670 16,614 

New Mexico 498 - 

New York 1,638 259,999 

North Carolina 1,671 - 

North Dakota 13 - 

Ohio 1,398 40,804 

Oklahoma 380 14,748 

Oregon 919 6,488 

Pennsylvania 3,617 57,481 

Rhode Island 125 1,636 
Enclosure II 

12 GAO-12-62R Pre-Existing Condition Insurance Plan Program

State PCIP enrollment CHIP enrollment 

South Carolina 504 40,768 

South Dakota 105 1,047 

Tennessee 419 12,445 

Texas 2,020 25,176 

Utah 395 2,653 

Vermont 0 - 

Virginia 424 - 

Washington 446 - 

West Virginia 30 161 

Wisconsin 676 - 

Wyoming 87 - 

Total 27,416 705,004 

Source: GAO analysis of data from CMS (PCIP data) and Mathematica Policy Research (CHIP data). 

Note: Enrollment totals for PCIP represent the number of individuals enrolled in June 2011, the final month of the first year of 

program coverage. Enrollment totals for CHIP represent the number of children ever enrolled during the final quarter of fiscal 

year 1998 (July - September 1998), including those who disenrolled before the end of the quarter. A dash indicates that the 

program had not yet been implemented. 
Enclosure III 

13 GAO-12-62R Pre-Existing Condition Insurance Plan Program 

States’ Status Regarding an Existing HRP and whether PCIP Was State- or 

Federally Run, 2010-2011 

State Did state have an existing HRP? Was PCIP state or federally run? 

Alabama Yes Federal 

Alaska Yes State 

Arizona No Federal 

Arkansas Yes State 

California Yes State 

Colorado Yes State 

Connecticut Yes State 

Delaware No Federal 

District of Columbia No Federal 

Florida Yes Federal 

Georgia No Federal 

Hawaii No Federal 

Idaho Yes Federal 

Illinois Yes State 

Indiana Yes Federal 

Iowa Yes State 

Kansas Yes State 

Kentucky Yes Federal 

Louisiana Yes Federal 

Maine No State 

Maryland Yes State 

Massachusetts No Federal 

Michigan No State 

Minnesota Yes Federal 

Mississippi Yes Federal 

Missouri Yes State 

Montana Yes State 

Nebraska Yes Federal 

Nevada No Federal 

New Hampshire Yes State 

New Jersey No State 

New Mexico Yes State 

New York No State 

North Carolina Yes State 

North Dakota Yes Federal 

Ohio No State 

Oklahoma Yes State 
Enclosure III 

14 GAO-12-62R Pre-Existing Condition Insurance Plan Program

State Did state have an existing HRP? Was PCIP state or federally run? 

Oregon Yes State 

Pennsylvania No State 

Rhode Island No State 

South Carolina Yes Federal 

South Dakota Yes State 

Tennessee Yes Federal 

Texas Yes Federal 

Utah Yes State 

Vermont No Federal 

Virginia No Federal 

Washington Yes State 

West Virginia Yes Federal 

Wisconsin Yes State 

Wyoming Yes Federal 

Source: GAO. 

Note: States’ status regarding an existing HRP was the same at the end of our review (September 2011) as it was when the 

PCIP program began (July 2010). 
Enclosure IV 

15 GAO-12-62R Pre-Existing Condition Insurance Plan Program 

Comments from the Department of Health and Human Services 
Enclosure IV 

16 GAO-12-62R Pre-Existing Condition Insurance Plan Program

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