When Congress struck a deal to avert the fiscal cliff, it also dealt a quiet blow to President Obama's health overhaul: The new law killed a multibillion-dollar program meant to boost health insurance competition by funding nonprofit health plans. The decision to end funding for the Consumer Operated and Oriented Plans has left as many as 40 start-ups vying for federal dollars in limbo. Some are considering legal action against the Obama administration, after many spent upwards of $100,000 preparing their applications.