Under the ACA, health insurance sold through an Association Health Plan (AHP) to small employers must meet the same insurance standards of coverage sold in the small-group market. However, research indicates that some AHPs are now claiming single large-group health plan status under ERISA, thus sidestepping the ACA requirements for the small-group market. Through interviews with state regulatory officials, health benefit consultants, association representatives and insurers, this paper examines the experience of the AHP market in Oregon. It finds that the AHP market continues to exist for small employers in Oregon and may be positioned for growth.