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To the editor: I read with complete astonishment the Aug. 31 letter to the editor, "...But Create Adverse Selection," which argued that proposed association health plans would create "adverse selection."

The comments in the letter by the president of the Health Insurance Assn. of America have no basis of fact, and included absurd generalizations such as:"these plans threaten to divide and conquer the small group marketplace," "healthier (AHP) groups will offer fewer benefits," and "AHPs would raise costs for less healthy employees and add thousands of people to the ranks of the uninsured."

The fact is: Today's state-regulated small group health insurance marketplace increases costs and restricts coverage levels for small employers that have high claim experience; and pre-existing condition requirements prohibit the open market benefits of a larger group which can fund the occasional high-cost claim.

I would have expected the president of the HIAA to support this exciting new initiative with conditions to implement "wellness programs" and "centers of excellence" for the high-end claim exposures, instead of burying his head in the sand and making short-sighted comments supporting the conventional methods that hurt the smaller employers.

Kevin J. Cunningham

Insurance Program Manager

Specialized Carriers & Rigging Assn.

Fairfax, Va.