In re the New Jersey Individual Health Coverage Program's

The opinion of the court was delivered by

STERN, P.J.A.D.

CIGNA Health Care of Northern New Jersey, CIGNA Health Care of New Jersey and Connecticut General Life Insurance Company (collectively referred to as “appellants” or “CIGNA”) appeal from the re-adoption on August 7, 1998 of the Individual Health Coverage Program (“IHCP” or “IHC Program”) regulations by the New Jersey Individual Health Coverage Program Board of Directors (“Board”).1 We granted U.S. Life Insurance Company the right to intervene.2

CIGNA argues (1) because the IHCP is “an association of private health insurers and not a state…