WASHINGTON -- The state and regional health-care purchasing alliance that would be formed under the legislation President Clinton sent to Congress yesterday would be required to finance their cash shortfalls with taxable, rather than tax-exempt, borrowings.

The White House's 1,300-page bill detailing the massive plan also contains a provision that some financial analysts contend could force states to use billions of dollars of tax-exempt bonds to bail out failed health plans formed by doctors and hospitals to provide guaranteed health benefits.

But a top administration official denied yesterday that the requirement that states set up such guaranty funds could lead to a big thrift-style bailout of doctors and hospitals by the states.

According to Ira Magaziner, a senior White House adviser who headed the health-care task force, the revenue to fund such bailouts would come through special assessments of up to 2% of the premiums paid to solvent health plans within the same regional alliances as the insolvent ones.

"The recourse will be to individuals and employers in those alliances, not to the state or federal government," Magaziner said in an interview.

Magaziner said he could not explain the decision to require the health alliances to borrow on a taxable basis either on the open market or by obtaining loans from the federal government. Because they would be organized as state agencies or non-profit corporations, bond lawyers and federal officials had previously said the alliances appeared to be eligible for tax-exempt status.

Magaziner said the alliances, which are expected to have a combined cash flow of around $700 billion a year, would have the same legal status as state-chartered insurance companies under the legislation.

Deputy Treasury secretary Roger Altman said the alliances would be authorized to borrow in the open market, but the Treasury is prohibiting them from claiming tax-exempt status. He said he was unfamiliar with a provision of the legislation also authorizing the alliances to obtain taxable federal loans.

Federal officials said the Treasury's tax-exempt bond experts earlier this year had expressed concern about the possibility that the health alliances, with their potentially huge short-term borrowing needs, could have access to the tax-exempt market.

The Treasury officials and some financial analysts feared that a massive onslaught of tax-exempt borrowing by the alliances could have an adverse effect on the municipal bond market as well as the Treasury's tax receipts.

The legislation stipulates that the loans the alliances would be eligible to receive from the government would have durations of up to two years only to cover temporary cash-flow shortfalls. The loans would carry interest rates close to the Treasury's own short-term taxable rates and would come with other strings attached.

The loans could be applied only to shortfalls attributable to discrepancies in the alliances' estimates of average insurance premiums within their regions, or to administrative error or time lapses between outlays and receipts.

In return for getting the loans, the Treasury could require the alliances to increase the average premiums charged to businesses and individuals within their regions.

The Treasury would ensure repayment of any loans made because of estimating errors or timing problems by withholding some of the subsidies it otherwise would give the alliances each year to help provide health coverage for small businesses and low-income individuals.

Loans that were provided because of administrative errors would be repaid with a temporary increase in payments that the states would have to make to the Treasury under the plan to compensate for coverage of Medicaid patients by the alliances.

Administration officials conceded that one factor eventually could force the alliances to step up borrowing: the White House's recent decision to put an overall cap on the amount of subsidies the federal government would provide for small businesses and low-income individuals.

The administration estimates that about one-quarter of its universal health-care plan would be financed with such federal subsidies, which would be paid directly to the regional alliances. If the subsidies fall short, the alliances might be forced to borrow to cover expenses.

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