The U.S. Capitol. Credit: Thinkstock

Association health plans created using regulations developed during Donald Trump's first term in the White House could provide coverage for about 600,000 people, according to analysts at the Congressional Budget Office.

AHPs could cover about 120,000 uninsured people and about 480,000 people who previously had individual or small-group coverage.

Some of the enrollees would be self-employed people and many others would be enrollees in small employer plans, the analysts predict.

The analysts used those assumptions when analyzing what a House AHP measure could do to the federal budget deficit. The suggested that the AHP program expansion could lead to $900 million in extra federal spending from 2025 through 2034 and cut federal income tax revenue by about $2 billion over that 10-year period.

The administration of President Joe Biden has blocked implementation of the Trump-era AHP regulations. The House measure, a resolution introduced by Rep. Tim Walberg, R-Minn., would overturn the Biden administration's action and let the AHP regulations take effect.
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Related: Association health plan bill is back, could reach House floor soon

Even if Congress fails to act on the AHP resolution, the CBO forecast gives hints about how the AHP regulations might work, and how big the AHP administration market opportunity might be, if the incoming Trump administration brings the regulations back to life.

AHP basics: Self-funded employer plans can already avoid state health insurance regulations, such as benefits mandates, because they operate under federal laws and are regulated by the U.S. Labor Department's Employee Benefits Security Administration, not by state insurance regulators.

Individuals, small employers and large employers that want fully insured health coverage can already join single-state AHPs regulated an AHP's state regulators. In some cases, employers that show they share a common interest can already join a multiple-employer welfare arrangement, but the current MEWA rules are complicated and differ from state to state.

The Trump AHP regulations came out in 2018 and lasted until Biden's Labor Department blocked them, in April 2024.


Walberg said when he introduced his resolution that employers using AHPs cut their health benefits costs by 29%.


AHP expansion opponents argue that AHPs limit enrollees' access to state patient protection rules and may drive premium costs for people with fully insured coverage, by causing healthier individuals and groups with less concern about benefits and coverage rules to move to the AHP market and leaving individuals and groups with more known health problems in the fully insured market.

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Allison Bell

Allison Bell, a senior reporter at ThinkAdvisor and BenefitsPRO, previously was an associate editor at National Underwriter Life & Health. She has a bachelor's degree in economics from Washington University in St. Louis and a master's degree in journalism from the Medill School of Journalism at Northwestern University. She can be reached through X at @Think_Allison.