The Farm Bill currently being debated in a House-Senate conference committee enables the Secretary of Agriculture to create a loan and grant program to assist in the establishment of agricultural association health plans (AHPs). The bill’s injection of federal funding for the purpose of creating new health insurance options is strikingly reminiscent of the ACA’s CO-OP Program. As Congress considers directing federal dollars into AHPs, we look back at the experience of the CO-OP program, which demonstrates just how difficult it is to build a new insurance company.