The large number
of uninsured children is universally acknowledged as a serious
problem, but policymakers have inappropriately fixated on
expanding the State Children's Health Insurance Program (SCHIP) as
the sole solution. Rather than expanding the role of SCHIP,
Congress should consider efforts to cover children in the broader
context of health reform by refocusing SCHIP to help children in
low-income working families, as originally intended, and
promoting policy prescriptions that reach beyond SCHIP and
improve the health care system for all Americans, including
In the context of
the upcoming SCHIP reauthorization, lawmakers should resist
efforts to rubber-stamp its reauthorization or to use SCHIP as a
vehicle to establish what amounts to a universal entitlement for
children. Instead, policymakers could help to refocus SCHIP and
advance new ways to address the needs of children that empower
families and strengthen access to private health care coverage.
Specifically, Congress should:
responsible system of program financing. Congress should
maintain the current block grant structure for SCHIP while
prioritizing funds to states that demonstrate fiscal prudence and
stay within the original context of the law by targeting
lower-income uninsured children. Congress should also limit
states' ability to secure additional federal taxpayer money to
cover their budget shortfalls.
eligibility rules. SCHIP was designed to help children in
lower-income working families at or below 200 percent of the
federal poverty level (FPL). States should retain flexibility
to experiment but keep within their budgets and federally
established income eligibility thresholds. SCHIP should not be
used as a mechanism to establish a welfare program for middle-class
or upper-middle-class families.
flexibility in health benefit design. Unlike Medicaid, which
targets truly low-income children, SCHIP was intended to target
children in families that earn too much to qualify for
Medicaid. Therefore, the SCHIP benefit package should resemble
private coverage more closely than Medicaid. To help families make
the transition into private coverage, SCHIP coverage options
should reflect the broadest array of insurance products
available in the private market.
private coverage alternatives. SCHIP should allow greater
opportunities to take advantage of private-sector health insurance
options. One way to do this would be to liberalize
administrative rules to facilitate premium assistance at the state
level and expand the availability of premium assistance
through SCHIP. Policymakers also should look beyond SCHIP for ways
to facilitate private insurance coverage for working families: for
example, by providing a refundable federal health care tax credit
to facilitate private-sector family coverage; allowing the
purchase of insurance across state lines; creating state-based
health insurance exchange mechanisms that facilitate the
purchase of individual, portable health care coverage; and
transforming existing subsidies for uncompensated care into direct
financial assistance to help families purchase private
A Clash of Visions
on Children's Health Coverage
The lack of
health insurance coverage among children reflects today's patchwork
health care system in which individuals, families, and
children slip through the cracks of the current
structure. While arguably the most politically attractive
group, children actually have one of the lowest uninsurance rates
relative to other age groups. The U.S. Census estimates that 11
percent of children were uninsured in 2005, compared to 31
percent of adults between the ages of 18 and 24. Policymakers would
be wise to consider proposals that benefit children as well as
other in-need populations by addressing the core problems of
the health care system instead of further compartmentalizing
groups and perpetuating this patchwork system.
uninsured-whether children or adults-do get care, but it is often
delayed and obtained in an inefficient and costly manner (e.g., in
hospital emergency rooms). Furthermore, surveys show that uninsured
children have less access to care than others. One study reports
that 54 percent of children without coverage have not made any
well-child visits and that 30 percent had no usual sources of care
in the past year.
The lack of
coverage also affects taxpayers. Researchers at the Urban Institute
found that federal, state, and local governments spent $34.6
billion on uncompensated care in 2004. Moreover, other
research shows that the uninsured are not the only ones underserved
by the system. Enrollees in poorly performing public programs,
specifically Medicaid and SCHIP, often cannot get the kind of care
they need and thus go to already overburdened hospital emergency
approach to addressing the problems of the nation's uninsured
children is to focus on program reauthorization, such as SCHIP, and
build on it as a model. This narrow approach ignores serious
structural changes-a typical Washington response to many public
policy issues-and can also be seen as an incremental
approach to expanding the role of government in the health
approach looks at the health care system as a whole and establishes
coherent and integrated policy prescriptions that address the
system's fundamental, core problems. This approach is far more
likely to provide longer lasting solutions that will improve the
health care system for all Americans, including children.
Approach. Two current legislative proposals are excellent
examples of the narrow, incremental approach: the Children's Health
First Act (S. 895 and H.R. 1535), introduced by Senator Hillary
Clinton (D-NY) and Representative John Dingell (D-MI), and S. 1224,
introduced by Senators John Rockefeller (D-WV) and Olympia
Snowe (R-ME). These bills rely on government-run models and
use SCHIP as the foundation to establish greater government control
over health care decisions affecting children. They also share
a common focus on enrolling more children in SCHIP, increasing
funding obligations for SCHIP to accommodate new enrollees, and
broadening the scope of eligibility and services in SCHIP.
Approach. President George W. Bush has outlined a more
comprehensive approach that incorporates SCHIP into a larger vision
that addresses the fundamental problems facing the health care
system. The President's proposal focuses on
maximizing existing SCHIP funds to cover low-income children;
reforming the federal tax treatment of health insurance to enable
families, regardless of job or job status, to receive federal tax
assistance to purchase private health insurance; and providing
states with greater flexibility to use federal funding to target
assistance more effectively to those who need it.
The Status Quo: How
SCHIP Works Today
reauthorizing SCHIP, Members of Congress should recall that
the program was enacted as part of the Balanced Budget Act of
to address coverage needs of low-income uninsured children whose
families earn too much to qualify for Medicaid but not enough
to purchase private coverage on their own.
Structure. Unlike Medicaid, which is an open-ended entitlement,
SCHIP was designed as a block grant, meaning that the program is
financed through a fixed appropriation. The legislation
appropriated $40 billion over 10 years, to be distributed
among the states.
These funds are
distributed to states based on a formula that accounts for a
variety of factors, including a state's number of low-income
uninsured children and differences in health care costs from
state to state. States receive a fixed, annual allocation based on
this formula and have three years to spend their allocation.
At the end of the three-year period, the Department of Health and
Human Services may recover and redistribute any unused funds. As an
enticement, states receive an enhanced Medicaid matching rate
ranging between 65 percent and 85 percent.
Over the years,
some states have spent more of their allotments than others,
creating a tension between the states that have depleted their
federal allotments and those that have not. In general, the
redistribution process rewards states that have overspent
their allotments at the expense of slower-spending states. As a
result, each state has a strong incentive to spend its allotment to
avoid losing it. In fiscal year (FY) 2001, 38 states and the
District of Columbia had unspent allotments, while 12 had spent
their original allotments. In FY 2006, only 11 states had unspent
allotments, compared to 39 states and the District of Columbia that
had exhausted their allotments, and 12 of these states faced
to shortfall states-those states that have overspent their original
allotments-are not a new phenomenon, but it was less obvious in the
past when the pool of unspent funds was larger. In FY 2001, over $2
billion in unused funds was available for redistribution, compared
to $173 million in FY 2006. Today, an estimated 14
states are facing shortfalls and are pressuring Congress to bail
them out. Besides some possible flaws in the basic
formula, SCHIP's overall funding structure encourages states
to leverage the enhanced SCHIP match, exceed their original
allotments, and go beyond the original scope of the program.
and Enrollment. The original legislation clearly defined
the populations eligible for SCHIP. The program targets low-income,
uninsured children and defines low-income children as those
whose family income is at or below 200 percent of the FPL
(approximately $40,000 for a family of four in 2007).
For states where Medicaid eligibility at the time of enactment was
near 200 percent of the FPL, the law allowed them to expand SCHIP
eligibility to 50 percent above their Medicaid levels.
Today, 25 states
and the District of Columbia have set SCHIP eligibility at 200
percent of the FPL, and nine states have set eligibility below 200
percent. Fifteen states have expanded eligibility
for children above 200 percent, and nine of the 15 have set it at
or above 300 percent of the FPL. Moreover, 10 of the 15 states
above 200 percent of the FPL have exceeded the 50 percent
pre-Medicaid threshold set in the law.
have used SCHIP funds to cover adults: Of these 15 states, 12 cover
parents, seven cover pregnant women, and seven cover childless
have played a role in these expansions. Many states have used
the broad terms of Section 1115 waivers to expand coverage up the
income scale and to various categories of adults. While
waivers are an important tool for states, giving them the
ability to develop innovative approaches to address the unique
needs of their populations, greater oversight and parameters may be
needed to ensure that states are not exceeding or exploiting the
fundamental goal of the program and, especially, its fixed funding
Design. States have some autonomy in designing their SCHIP
programs. A state can expand the existing Medicaid program, set up
a separate program, or use a combination of the two. States
have adopted all three approaches: 10 states and the District of
Columbia have a Medicaid expansion, 18 states have a separate
program, and 22 states use combination approaches.
If a state
expands its existing Medicaid program to meet SCHIP requirements,
Medicaid rules and benefits must apply. A different set of rules
and benefit standards are established for states that set up a
separate program. Specifically, a state can meet the benefit
of the "benchmark" benefit packages listed in law,
actuarial equivalent plan to a benchmark,
existing comprehensive state-based program, or
approval from the Secretary of Health and Human Services for an
Under a separate
SCHIP structure, states can also require cost-sharing (e.g.,
premiums or co-pays). As noted, the goal of SCHIP was to
provide assistance to children whose families earn too much to
qualify for Medicaid but not enough to afford private coverage.
Thus, implementing cost-sharing requirements helps to
differentiate SCHIP from Medicaid, which is intended to service the
truly poor, and cost-sharing better prepares these working families
for eventual transition into private coverage.
states have weakened this distinction by removing or diluting
any cost-sharing requirements. In FY 2005, 11 states required no
cost-sharing, 14 charged only premiums, and nine charged only
co-pays. Furthermore, the range in premiums and
co-pays varied significantly.
Passage of the
Deficit Reduction Act of 2006 raises further questions about
SCHIP's benefit package. It gives states greater flexibility to
design their Medicaid benefit packages and cost-sharing
requirements to resemble SCHIP more closely. While these changes
are good for Medicaid, this further reduces the distinction between
the two programs. New thinking on SCHIP's coverage options and
cost-sharing is in order, such as adding new coverage options
and cost-sharing standards that better reflect the private
sector and prepare families for private coverage.
Assistance. States can leverage the private coverage option for
enrollees through premium assistance, but the level of
bureaucracy involved in implementing this option makes it
unattractive and not cost-effective for many states. "Premium
assistance" typically means that an SCHIP child enrolls in the
parent's employer-based coverage and SCHIP pays a share of the
child's premium. However, to do this, a state must determine
whether the employer's benefit package matches the SCHIP benchmark
and provide a "wraparound" to fill in benefit and cost-sharing
differences. Today, only 12 states offer a premium assistance
The obstacles to
premium assistance illustrate the backward thinking about SCHIP.
SCHIP's proponents often view government-controlled SCHIP
coverage for children as preferable to empowering families to
purchase their own coverage from the private market where the vast
majority of Americans get their coverage. In addition, there
seems to be a sense that private coverage is not a viable option
for low-income families, yet an estimated 10.4 million children
below 200 percent of the FPL have private coverage.
Broadening the applicability of SCHIP premium assistance would
be a valuable and attractive tool in helping SCHIP children to
obtain private coverage with their families.
Building on a Flawed Status Quo
reauthorization of SCHIP provides a vehicle for policymakers to
address the obstacles to children's coverage, but SCHIP is not
the only solution. Nor is it the ideal setting to address the needs
of working families. Policymakers should be cautious and consider
the implications of proposals that focus solely on SCHIP as the
Creep. The government already provides health care for a
staggering number of children, and efforts focused on
enrolling all eligible children in these programs will only
increase this dependence on the government. In 2005, an
estimated 45 percent of all children were covered by Medicaid
or SCHIP, compared to 28 percent in 1998. Recent research suggests
that a significant number of uninsured children are eligible but
not enrolled in SCHIP or Medicaid. Those who support
expanded government control over the delivery of health care
reference such research and argue that policymakers should fund and
facilitate greater outreach for enrollment.
establishing a policy of enrolling all eligible children goes
far beyond the program's original intent and is in reality a
thinly veiled attempt to convert SCHIP into a new entitlement.
Establishing a federal goal of enrolling all eligible children
would move SCHIP closer to an entitlement and make it the primary
source of coverage for more children instead of a safety net for
those who cannot secure coverage in the private sector. American
taxpayers are already saddled with massive financial
obligations for Medicare and Medicaid. They cannot afford
another health care entitlement program.
Mandate. Policymakers should also consider the fiscal realities
of the existing SCHIP program. Like Medicaid, it is based on a
state-federal matching system in which both the states and the
federal government contribute to the program. States are
already struggling to maintain their budgets, and Medicaid has
become the largest budget item, surpassing the traditional
state obligations of education and transportation. Efforts to enroll
more children in the SCHIP program would undoubtedly impose an even
larger burden on state budgets.
expanding outreach efforts and simplifying the enrollment
process would significantly diminish the states' ability to adopt
policies to keep the program fiscally manageable. Moreover, if the
recent practice among some states of depending on federal bailouts
of their SCHIP shortfalls continues, federal taxpayers will also be
tasked with covering future shortfalls.
Private Health Care Coverage. Congress should exercise extreme
caution when expanding any public health care program. The
unintended consequences often include loss of private coverage
and reductions in private spending for health care, which is
replaced by an increased public spending.
empirical research on the extent of the "crowd-out" effect-declines
in private coverage caused by expansion of a public program-is
mixed, there is absolutely no doubt that it exists. The latest
research by economists Jonathan Gruber and Kosali Simon suggests an
approximate 60 percent crowd-out effect. Thus, Congress
should not undertake SCHIP expansions without understanding
the level of damage that such policies can inflict on existing
private-sector options, especially for the family as a whole.
Improving SCHIP and
help to refocus SCHIP and advance new ways to address the needs of
children that are consistent with empowering families and
strengthening access to private health care coverage. Policymakers
should look at ways to improve SCHIP and expand availability for
private coverage for children, preferably while addressing the
fundamental shortfalls of the entire health care system.
Responsible System of Financing. Specifically, Congress
block grant structure. Keeping the block grant structure would
allow states to continue to receive federal assistance to address
the needs of targeted low-income children while limiting their
financial dependence on the federal government and protecting
taxpayers from funding yet another fiscally unsustainable
entitlement program. Congress should reinforce the block grant
financing structure. Without it, the existing fiscal abuses will
continue and grow much worse.
funding to states that focus on targeted low-income
There is great debate as to whether or not the
current system for calculating state allocations accurately
reflects state dynamics.
While states arguably need a more
accurate and reliable formula structure, policymakers should
incorporate an approach that gives priority attention to states
that stay within the federal eligibility thresholds and demonstrate
redistribution of unspent funds among states. One of the most
contentious issues in state allocations is the process of
redistributing unspent funds. While well-intentioned, the
current policy rewards states for overspending and encourages
other states to follow suit or risk losing their allotments.
Moreover, simply allowing states to keep these federal funds
indefinitely is also not effective. A better approach would allow
states to carry over funds for a specific number of years, with any
funds still unspent after that time to revert to the U.S.
states' ability to leverage Medicaid financing. Under SCHIP, if
a state expands Medicaid to accommodate SCHIP enrollees, the
state can revert to lower Medicaid matching rates to finance
shortfalls or additional coverage. Unlike SCHIP matching funds,
which are limited under the block grant, Medicaid matching funds
are unlimited. Thus, states that use this technique as a fallback
can receive unlimited federal matching through Medicaid.
Policymakers should restrict the states' ability to use this
financing technique for Medicaid expansions and resist efforts to
expand this practice to separate SCHIP plans.
Eligibility Rules.Congress should:
children at or below 200 percent of the FPL. SCHIP should focus
primarily on addressing the coverage needs of children at or below
200 percent of the federal poverty level. Although some states have
gone beyond this income target and others are proposing going even
further, such expansions risk eroding private coverage options
for working families and creating a welfare program for
middle-class and upper-class families. Policymakers should resist
efforts to expand SCHIP eligibility beyond 200 percent of the
parameters on state flexibility. While the SCHIP law clearly
targets children below 200 percent of the FPL, some states have
used the waiver process to expand coverage beyond income thresholds
and to populations other than children. While federal policymakers
should preserve state flexibility, they should establish clear
parameters for such flexibility. Specifically, a state requesting a
waiver to expand coverage must do so within its original federal
allotments, and this funding limitation should be strictly
enforced at the federal level. In addition, a state requesting to
expand coverage to non-children should demonstrate that it has
fulfilled its obligation to targeted children. Finally,
expanding coverage above the 200 percent FPL threshold should
be strictly prohibited. If states wish to expand beyond this income
level, they should do so with only state funds.
Flexibility in Health Benefit Design.Congress should:
benefit choices beyond traditional benchmarks.
states to design an SCHIP benefit based on a benchmark plan.
These plans tend to set the benchmark very high and do not
reflect current private coverage options or trends. Instead of
further distancing SCHIP benefits from existing private
coverage models, policymakers should encourage states to
broaden the coverage options available within SCHIP. For example,
consumer-directed products promote value by engaging individuals in
their health care decisions. An estimated 4.6 million people were
covered by either a health savings account (HSA) plan or a health
reimbursement arrangement as of January 2007.
survey found that 50 percent of HSA purchasers earned less than
$50,000 per year.
basic cost-sharing in SCHIP. States can require cost-sharing
(e.g., premiums and co-pays) for SCHIP, but many of these
cost-sharing requirements are negligible. SCHIP targets
children in working families; thus, coverage should help to prepare
and mainstream these families into private coverage, and this
includes cost-sharing. Policymakers should set some explicit
cost-sharing requirements for enrollees based on income and oppose
efforts to minimize these standards.
Private Coverage.To facilitate the availability and
affordability of private coverage, Congress should:
administrative and regulatory rules on premium assistance.
While SCHIP and even Medicaid allow for premium assistance, the
rules and regulations make it too administratively difficult
and burdensome to be a practical option for states or families.
Policymakers should make it easier for families to leverage SCHIP
funds to enroll their children in private coverage, whether through
an employer or on their own, without the administrative hassles of
the existing process. Policymakers should also require states to
offer premium assistance as an option to families and enable states
to require participation in premium assistance.
premium assistance model. The current model for premium
assistance is designed to help a family pay for its share of a
child's premium, but many parents may face other cost-sharing
requirements for their children in the private market. Thus,
policymakers should expand the SCHIP premium assistance model to
allow SCHIP funds to be used for premiums and other
cost-sharing requirements (e.g., deductibles, co-pays, and even
savings for future health care needs). This will also help to move
SCHIP from a defined benefit model to a defined contribution
incentives for parents to obtain family coverage in the private
market. The current tax treatment of health insurance
discriminates against lower-income workers and families. Thus,
for many low-income families, SCHIP is the only affordable option
for their children. Policymakers should fix this inequity by
building on the President's health care tax proposal.
Specifically, they should give parents a tax subsidy (a tax
credit or a deduction) to assist them in obtaining private
coverage, either through their employers or independently, and
should allow parents with SCHIP-eligible children to use SCHIP
funds to supplement the tax benefit for family coverage.
private-sector coverage options.
Expanding the availability of
affordable, private coverage options is important to helping
lower-income working families obtain private health insurance.
Allowing individuals to purchase coverage from outside their
own states, establishing state-based health insurance exchanges,
and transforming existing subsidies into direct financial
assistance to help families purchase private coverage are three
ways to increase the availability and affordability of
or-worse-expansion of the SCHIP status quo is unacceptable. It sets
the program on a path toward becoming an entitlement, adds
additional fiscal burdens on states and federal taxpayers, and
even crowds out existing private coverage.
rectify these problems by creating a responsible system of
financing for the program, establishing rational eligibility
standards targeted to children in lower-income families that need
the most help, expanding coverage options, and promoting
private-sector alternatives for lower-income working families.
reauthorization is a historic opportunity for lawmakers to address
the health care needs of children. Congress can best address the
coverage needs of children by incorporating SCHIP as a
component of larger and more sweeping reforms of the health
insurance market. Successfully reforming SCHIP would be a major
step toward expanding and improving the health care system for
children, their parents, and all Americans.
is Senior Policy Analyst for Health Care in the Center for Health
Policy Studies at The Heritage Foundation.
DeNavas-Walt, Bernadette D. Proctor, and Cheryl Hill Lee, "Income,
Poverty, and Health Insurance Coverage in the United States: 2005,"
U.S. Department of Commerce, U.S. Census Bureau, August 2006, p.
22, at (April 24,
 Campaign for
Children's Health Care, "No Shelter from the Storm: America's
Uninsured Children," September 2006, p. 9, at
(April 24, 2007).
 Jack Hadley,
Ph.D., and John Holahan, Ph.D., "The Cost of Care for the
Uninsured: What Do We Spend, Who Pays, and What Would Full Coverage
Add to Medical Spending?" Kaiser Commission on Medicaid and the
Uninsured Issue Update, May 10, 2004, p. 3, at
(April 24, 2007).
"Hillary Care Installment Plan," The Wall Street Journal,
April 24, 2007, p. A18, at
(April 27, 2007).
 See The White
House, "Strengthening Health Care," at
(April 24, 2007).
appropriations were about $4.2 billion for FY 1998-FY 2001, $3.2
billion for FY 2002-FY 2004, $4.1 billion for FY 2005-FY 2006, and
$5 billion for FY 2007. Elicia J. Herz, Bernadette Fernandez, and
Chris L. Peterson, "State Children's Health Insurance Program
(SCHIP): A Brief Overview," Congressional Research Service
Report for Congress, August 4, 2005, p. 5.
 Kathryn G.
Allen, Director, Health Care, U.S. Government Accountability
Office, "Children's Health Insurance: States' SCHIP Enrollment and
Spending Experiences in Implementing SCHIP and Considerations for
Reauthorization," statement before the Subcommittee on Health,
Committee on Energy and Commerce, U.S. House of Representatives,
February 15, 2007, GAO-07-447T, p. 29, at
(April 24, 2007).
Peterson, "Federal SCHIP Financing: Testimony Before the Senate
Finance Health Subcommittee," Congressional Research Service, July
25, 2006, p. 1, at (April 24,
 $650 million
in bailout funding was included in the FY 2007 emergency
supplemental appropriations conference agreement but, as of this
writing, is pending the President's signature or veto.
 42 U.S. Code
provided by U.S. Department of Health and Human Services, Centers
for Medicare and Medicaid Services, October 5, 2006.
Arizona, Colorado, Idaho, Illinois, Michigan, Minnesota, Nevada,
New Jersey, New Mexico, Oregon, Rhode Island, Utah, Virginia, and
Wisconsin. Allen, "Children's Health Insurance," p. 22.
Department of Health and Human Services, Centers for Medicare and
Medicaid Services, "The State Children's Health Insurance Program,"
PowerPoint presentation, March 5, 2007, p. 6.
options include the standard BlueCross BlueShield preferred
provider option in the Federal Employees Health Benefits Program, a
state employee health benefit plan, and the largest HMO in the
 As noted,
SCHIP Medicaid expansions must follow Medicaid cost-sharing
"Children's Health Insurance," p. 18.
 Ibid., p. 19. See also Donna
Cohen Ross, Laura Cox, and Caryn Marks, "Resuming the Path to
Health Coverage for Children and Parents: A 50 State Update on
Eligibility Rules, Enrollment and Renewal Procedures, and
Cost-Sharing Practices in Medicaid and SCHIP in 2006," Henry J.
Kaiser Family Foundation, January 2007, pp. 59-62, at (April 24,
Department of Health and Human Services, "The State Children's
Health Insurance Program," p. 14.
 Ibid., pp. 18 and 19.
Holahan, Allison Cook, and Lisa Dubay, "Characteristics of the
Uninsured: Who Is Eligible for Public Coverage and Who Needs Help
Affording Coverage?" Kaiser Commission on Medicaid and the
Uninsured Issue Paper, February 2007, at
(April 24, 2007).
Governors Association and National Association of State Budget
Officers, "The Fiscal Survey of States," December 2006, p. 1, at
"The Truth About SCHIP Shortfalls."
Gruber and Kosali Simon, "Crowd-Out Ten Years Later: Have Recent
Public Insurance Expansions Crowded Out Private Health Insurance?"
National Bureau of Economic Research Working Paper No.
12858, January 2007.
"Federal SCHIP Financing."
 This number
includes individual, small-group, and large-group markets. See
American's Health Insurance Plans, Center for Policy and Research,
"January 2007 Census Shows 4.5 Million People Covered by
HSA/High-Deductible Health Plans," April 2007, at
(April 24, 2007).
 eHealthInsurance, "Health Savings
Accounts: January 2005-December 2005," May 10, 2006, p. 9, at (April 27, 2007).
 For more
information on the state-based health insurance exchange, see
Robert E. Moffit, Ph.D., "The Rationale for a Statewide Health
Insurance Exchange," Heritage Foundation WebMemo No. 1230,
October 5, 2006, at www.heritage.org/Research/HealthCare/wm1230.cfm.