BILL ANALYSIS SENATE HEALTH COMMITTEE ANALYSIS Senator Elaine K. Alquist, Chair BILL NO: AB 1826 A AUTHOR: Huffman and Feuer B AMENDED: May 28, 2010 HEARING DATE: June 30, 2010 1 CONSULTANT: 8 Chan-Sawin/cjt 2 6 SUBJECT Health care coverage: prescriptions SUMMARY Requires a health care service plan (health plan) or health insurer that covers outpatient prescription drug benefits to provide coverage for a drug that has been prescribed for the treatment of pain. Prohibits the health plan or insurer from requiring the subscriber or enrollee to first use an alternative prescription drug or over-the-counter drug, as specified. CHANGES TO EXISTING LAW Existing federal law: Defines, under the federal health reform law, the Patient Protection and Affordable Care Act (PPACA), a list of "essential health benefits package," including prescription drug coverage, which health insurance coverage and group health plans must provide, beginning in 2014. Existing law: Provides for the regulation of health plans and insurers by the Department of Managed Health Care (DMHC) and the Continued--- STAFF ANALYSIS OF ASSEMBLY BILL 1826 (Huffman, Feuer) Page 2 California Department of Insurance (CDI), respectively. Prohibits health plans and insurers that cover prescription drugs from limiting or excluding coverage for a drug on the basis that the drug is prescribed for a use different from the use for which the drug has been approved by the federal Food and Drug Administration (FDA), provided that specified conditions have been met (including that the drug is prescribed by a participating licensed health care professional for the treatment of a chronic and seriously debilitating condition, the drug is medically necessary to treat that condition, and the drug is on the plan formulary). Prohibits health plans covering prescription drug benefits from limiting, or excluding coverage for a drug for an enrollee, if the drug was previously approved for coverage by the plan for a medical condition of the enrollee and the plan's prescribing provider continues to provide the drug for the medical condition, provided that it is safe and effective for treatment. This prohibition does not preclude the prescribing provider from prescribing another drug that is covered by the plan and is medically appropriate, nor does it prohibit generic drug alternatives. Requires health plans that provide prescription drug benefits, and maintain one or more drug formularies, to provide to the public, upon request, a copy of the most current list of prescription drugs by major therapeutic category, with an indication of whether any drugs on the list are preferred over other listed drugs. Requires plans that maintain more than one formulary to notify the requester that a choice of formulary lists is available. Requires health plans that provide prescription drug benefits to maintain an expedited process by which prescribing providers may obtain authorization for a medically necessary non-formulary drug. Requires any health plan disapproval to provide the enrollee with the reasons for the disapproval, and notify the enrollee of the right to file a grievance if the enrollee objects to the disapproval, as specified. Requires the process for authorization of medically STAFF ANALYSIS OF ASSEMBLY BILL 1826 (Huffman, Feuer) Page 3 necessary non-formulary drugs to be described in the health plan disclosure form. Requires, in regulations, health plans that cover outpatient prescription drug benefits to cover all medically necessary outpatient prescription drugs, as specified. This bill: Requires a health plan or insurer that covers outpatient prescription drug benefits to provide coverage for a drug that has been prescribed by a participating licensed health care provider for the treatment of pain. Prohibits the health plan or insurer from requiring the subscriber or enrollee to first use an alternative prescription drug or over-the-counter drug, but allows the health plan or insurer to require the subscriber or enrollee to first use a generically equivalent drug. Defines "generically equivalent drug" to mean drug products with the same active chemical ingredients of the same strength, quantity, and dosage form, and of the same generic drug name, as determined by the United States Adopted Names Council and accepted by the federal Food and Drug Administration, as those drug products having the same chemical ingredients. Specifies that nothing in this bill prohibits a health plan or insurer from charging copayments or deductibles for prescription drug benefits or imposing limitations on maximum coverage of prescription drug benefits, as specified. Exempts a health plan or health insurance policy purchased by the California Public Employees' Retirement System (CalPERS) from the requirements of this bill. Prohibits this bill from being construed to require coverage of prescription drugs not in a health plan or insurer's drug formulary, or to prohibit use of generically equivalent drugs or generic drug substitutions, as specified. FISCAL IMPACT STAFF ANALYSIS OF ASSEMBLY BILL 1826 (Huffman, Feuer) Page 4 According to the Assembly Appropriations Committee analysis, unknown increased costs to Medi-Cal and the Healthy Families program in the range of $5 million (50 percent General Fund (GF) and 33 percent GF, respectively). Although recent amendments address brand name drug cost pressures, many drugs that remain under patent do not have generic versions available. BACKGROUND AND DISCUSSION According to the author, p ain is a growing national public health crisis that affects an estimated 76 million people and has serious economic ramifications , and that c hronic pain affects more Americans than diabetes, heart disease, and cancer combined. The author points to a 2006 survey by the National Center for Health Statistics which states that the annual cost of chronic pain in the U.S., including health care expenses, lost income, and lost productivity, is about $100 billion. The author states that a troubling and dangerous trend is the frequent denial of coverage by health plans and insurers for proven and effective pain treatments. Used as a cost-saving measure, many health plans and insurers utilize step therapy or " fail - first " policies , which require a patient in pain to try an alternative medication, which in some cases include over-the-counter medications, before the medication recommended by the physician is approved. The author points out that s ome patients are required to try up to five different medicines before receiving the one prescribed by their physician and , more often than not, the alternative drugs have a completely different molecular structure that can be harmful to patients . While insurers argue that step therapy is helpful in managing rising drug costs, the author questions the basic fairness of denying coverage for a drug that a doctor believes is the most effective drug for the treatment of someone who is, oftentimes, in severe, debilitating pain. The author believes that it is essential that patients in pain receive the drug treatment prescribed by their physicians and do not suffer the needless consequences caused by step therapy. STAFF ANALYSIS OF ASSEMBLY BILL 1826 (Huffman, Feuer) Page 5 The author also asserts that, n ot only is this policy extremely dangerous to patient health, step therapy can actually increase the direct cost of health care in the long run , due to increased emergency room visits, unplanned doctor's visits, and other health complications. Indirect costs include lost wages and productivity of both people with pain and their caregivers. The author points to findings from a recent study published in the February 2009 issue of the American Journal of Managed Care, that suggests that step therapy programs may increase overall health care costs for employers. In the study, researchers analyzed insurance claims data from 2003 through 2006 for 11,851 people with employer-sponsored health coverage that incorporated a step therapy protocol for anti-hypertensive drugs, and compared their use of health care services to a group of 30,882 anti-hypertensive drug users who did not participate in a step therapy program. What the researchers found was that the group of patients treated for hypertension under the step therapy program had 3.1 percent lower drug costs. But these savings were wiped out by the increase in hospital admissions and emergency room visits. Pain and pain management According to the American Academy of Pain Management, pain is a silent epidemic in the United States. An estimated 50 million Americans live with chronic pain caused by disease, disorder or accident. An additional 25 million people suffer acute pain resulting from surgery or accident. Approximately two-thirds of these individuals in pain have been living with their pain for more than five years. The most common types of pain include arthritis, lower back, bone/joint pain, muscle pain, and fibromyalgia. The loss of productivity and daily activity due to pain is substantial. According to the American Pain Society, pain is the second leading cause of medically related work absenteeism, resulting in more than 50 million lost workdays annually. According to a 2006 survey by the National Center for Health Statistics (NCHS), back pain is the leading cause of disability in Americans under 45 years old, and more than 26 million Americans between the ages of 20 to64 experience frequent back pain. The NCHS survey also indicated that STAFF ANALYSIS OF ASSEMBLY BILL 1826 (Huffman, Feuer) Page 6 adults who reported low back pain were three times as likely to be in poorer health and more than four times as likely to experience serious psychological distress as people without low back pain problems. The survey estimated that the annual cost of chronic pain in the U.S., including health care expenses, lost income, and lost productivity is about $100 billion. Pain management is a branch of medicine employing an interdisciplinary approach to easing the suffering and improving quality of life of those living in pain. According to the National Institutes of Health (NIH), common treatments for pain include medication, acupuncture, local electrical stimulation, brain stimulation, surgery, psychotherapy, relaxation therapy, biofeedback, and behavior modification. Step therapy In its analysis of this bill (described in detail later in this analysis), CHBRP defines "fail-first protocols" as the group of utilization management techniques that would be prohibited by this bill for pain medications. Step therapy, also known as "step edit" is one type of "fail-first" protocol; others include generic substitution or certain types of prior authorization protocols. According to a 2001 report by the California HealthCare Foundation (CHCF) relating to prescription drug coverage and formulary use in California, step therapy requires patients and physicians to follow a particular sequence of drug treatment. In general, a patient must fail to respond to a recommended first-line therapy before a second- or third-line medication is prescribed. Typically, this means that patients will be required to try medications that have been on the market for a longer period of time and are usually less expensive than the newer medications available to treat a specific condition. For example, the CHCF report suggests that newer inhibitors for the relief of arthritic pain, such as Celebrex, which are part of a large class of anti-inflammatory drugs, may be subject to step therapy requirements. Generic substitution vs. therapeutic substitution. Generic substitution refers to the substitution of a brand name drug for a generic drug that is the chemical equivalent and STAFF ANALYSIS OF ASSEMBLY BILL 1826 (Huffman, Feuer) Page 7 the same dosage of the brand name. Therapeutic substitution refers to the substitution of one drug with a chemically different drug within the same therapeutic category (that is used for the treatment of the same condition). For example, aspirin is the therapeutic equivalent of ibuprofen, even though they are chemically different, as they are used for the treatment of the same condition. The California Health Benefits Review Program (CHBRP) Pursuant to AB 1996 (Thomson), Chapter 795, Statutes of 2002, and SB 1704 (Kuehl), Chapter 684, Statutes of 2006, the University of California is requested to assess legislation proposing a mandated benefit or service, or the repeal of a mandated benefit or service, through the California Health Benefits Review Program (CHBRP). CHBRP prepares a written analysis of the public health, medical, and economic impacts of such measures. Earlier versions of AB 1826 would have prohibited health plans and insurers from using all fail-first protocols in determining outpatient pharmacy benefit coverage for pain medication. The May 28, 2010 version of this bill would allow the use of one type of fail-first protocol, generic substitution, while still prohibiting others. Pursuant to a letter from CHBRP, dated June 23, 2010, the cost impact analysis of their April 16, 2010 report would change. The following are highlights from the CHBRP analysis, including the applicable changes to the cost impact section as noted in the June 23, 2010 letter: Assumptions of the analysis Prescription medications may be covered as inpatient medical benefits, and/or through an outpatient pharmacy benefit, if included in the plan contract or insurance policy. Some plan contracts or insurance policies do not include outpatient pharmacy benefits. The CHBRP report assumes that AB 1826 would not increase the number of enrollees with an outpatient prescription drug benefit. Providers, independent of plan or policy protocols, may choose to utilize fail-first protocols by requiring patients to try any number of alternate medications before prescribing a particular pain STAFF ANALYSIS OF ASSEMBLY BILL 1826 (Huffman, Feuer) Page 8 medication. The report also assumes that provider prescribing practices would not be subject to AB 1826. Potential impact of federal health care reform In March of this year, the President signed the federal health reform law, the Patient Protection and Affordable Care Act (PPACA). PPACA would make significant changes to the California health insurance market and its regulatory environment. Effective January 1, 2014, PPACA requires health plans and insurers to provide coverage for "essential health benefits," as defined by the Secretary of the Department of Health and Human Services. Included in the list of required "essential health benefits" is coverage of prescription drugs. How these provisions are implemented in California would depend on regulations from federal agencies, and statutory and regulatory actions taken by the state. PPACA also includes provisions that take effect by September 2010, which would expand the number of Californians with insurance, such as requiring coverage for dependents up to age 26. This would decrease the number of uninsured and increase the number of people impacted by this mandate. The CHBRP analysis does not reflect the impact from implementation of federal health reform requirements. Medical effectiveness Due to the variety of causal conditions and types of pain (acute and chronic), there is no standard treatment for pain. Pain treatment varies according to type, severity, and duration of pain, as well as the causal condition (if known), patient co-morbidities, and other factors (e.g., medication intolerance or patient compliance). Health care providers use clinical judgment to select among various pain medications and treatments in efforts to resolve or control pain for individual patients. CHBRP found no medical effectiveness literature addressing the direct effects of fail-first protocols on resolving or controlling pain. Of more than 200 prescription medications used to treat pain, CHBRP reported that 54 were subject to STAFF ANALYSIS OF ASSEMBLY BILL 1826 (Huffman, Feuer) Page 9 fail-first protocols for at least some portion of enrollees with health insurance subject to this bill. However, among the 54 medications identified, there is variation in frequency of medications subject to fail-first protocols. It is not clear which of these medications, if any, would be subject to generic substitution, as allowed for under the most recent version of the bill. Additionally, CHBRP found insufficient evidence to characterize the medical effectiveness of fail-first protocols for pain medications. Therefore, CHBRP concluded that the impact of this bill on the medical effectiveness of pain treatment is unknown, and points out that the lack of evidence for the effectiveness of fail-first protocols is not evidence that these protocols produce either positive or negative health outcomes. Impact on coverage Not all enrollees and insureds have an outpatient pharmacy benefit. Of those who do, not all of the pain medications are subject to any fail-first protocol. For some enrollees, no pain medications are subject to fail-first protocols. Other enrollees, depending on the provisions of their plan contracts or insurance policies, have anywhere between 1 and 38 (out of the 54) pain medications, that is covered by their outpatient pharmacy benefits, that is subject to fail-first protocols. It is not clear which of these medications, if any, would be subject to generic substitution, as allowed for under the most recent version of the bill. According to CHBRP, it is possible that two enrollees with plan contracts from a single health plan (or policies from a single insurer) might not have outpatient pharmacy benefits for pain medications that are subject to the same list of fail-first protocols - or one of them might not be subject to any list at all. About 18.7 million enrollees in DMHC-regulated health plans or CDI-regulated policies have health insurance subject to this bill. CHBRP assumed that this bill would not increase the number of enrollees with an outpatient pharmacy benefit. CHBRP reports that 18.1 STAFF ANALYSIS OF ASSEMBLY BILL 1826 (Huffman, Feuer) Page 10 million, or 97.2 percent, of insured Californians have outpatient pharmacy benefit coverage. Of these: 8.3 million enrollees (45.5 percent) have pharmacy coverage subject to fail-first protocols for one or more pain medications. 9 million enrollees (49.3 percent) have pharmacy coverage that is not subject to any fail-first protocols and not affected by this bill. There are 417,000 enrollees (2.2 percent) who have generic-only outpatient pharmacy benefit coverage and would not be affected by this bill. There are also 521,000 insured Californians (2.8 percent) who do not have outpatient pharmacy coverage and would not be affected by this bill. CHBRP confirmed that a portion of beneficiaries in Medi-Cal, the Healthy Families program, Access for Infants and Mothers (AIM) Program, and the Major Risk Medical Insurance Program (MRMIP) have outpatient pharmacy benefits for pain medication that is subject to some fail-first protocols. However, as was found to be the case for privately funded health insurance, the presence of fail-first protocols varied by plan. Impact on utilization According to CHBRP, 610 per 1,000 enrollees receive prescriptions for identified medications approved by the FDA and commonly used for pain, both generic and brand name, over the course of one year. This bill is not expected to measurably affect this number because outpatient pharmacy benefit coverage is not expanded by this bill. AB 1826 is also not expected to result in an increase in diagnosis or treatment of pain. This bill is expected to affect the percentage of filled pain prescriptions that are for generic versus brand name medications, but the extent is unclear given the recent amendments. Impact on cost In its report released April 16, 2010, CHBRP estimates total net expenditures (including premiums and STAFF ANALYSIS OF ASSEMBLY BILL 1826 (Huffman, Feuer) Page 11 out-of-pocket expenses) for prescriptions for pain medications would increase by about $27.7 million or 0.04 percent due to this bill. Total premiums for private employers are expected to increase by about $9.3 million or 0.02 percent. Premiums for individually purchased insurance are expected to increase by about $2 million or 0.03 percent. Enrollee out-of-pocket expenses are also estimated to increase by approximately $3.19 million or 0.05 percent. The average cost per prescription associated with pain medications on at least one fail-first protocol list is projected to increase $30, or 14 percent. The post mandate increase in average cost per prescription reflects a decrease in use of generic, and an increase in use of brand-name, medications. The per-unit cost of the medications themselves is not expected to increase. Medi-Cal expenditures are estimated to increase by about $8.12 million, or 0.2 percent, and state expenditures for Healthy Families, AIM, and MRMIP are estimated to increase by about $2.10 million or 0.2 percent. This is an increase of $0.24 per member per month (PMPM) for Medi-Cal, Healthy Families, AIM, and MRMIP. Expected PMPM increases in other market segments are as follows: $0.08 PMPM in large-group market DMHC-regulated plans; $0.11 PMPM in large-group marked CDI-regulated policies; $0.11 PMPM in small-group market DMHC-regulated plans; $0.17 PMPM in small-group market CDI-regulated policies; $0.10 PMPM in individual market DMHC-regulated plans; and, $0.10 PMPM in individual market CDI-regulated policies. Per the June 23, 2010 CHBRP update letter, these cost projections would likely be lower. However, the extent to which the cost estimates would decrease would require another analysis, since the underlying analytic approach would need to be re-assessed. Specifically, the approach for identifying the number of medications on fail-first protocol lists, and the number of enrollees affected, may need to be modified. STAFF ANALYSIS OF ASSEMBLY BILL 1826 (Huffman, Feuer) Page 12 Public health impact CHBRP reports that, although there is some evidence that fail-first protocols can lead to lower levels of patient satisfaction, delays in receiving medications, and higher rates of unfilled prescriptions, this research is not generalizable to populations outside of those studied . Therefore, the public health impact of this bill is unknown. Additionally, CHBRP was unable to determine the extent to which this bill would impact people of different genders or racial/ethnic groups differentially. Lastly, CHBRP states that pain conditions are known to be relevant factors in terms of lost productivity and associated economic loss through days missed from work as well as reduced ability to perform tasks at work. However, no research was identified that assessed the impact of fail-first protocols for pain medications on measures of productivity. Therefore, the impact of this bill on lost productivity and economic loss associated with conditions requiring the use of pain medications is unknown. Arguments in support The sponsor of this bill, For Grace, writes that this bill highlights the inadequacies of step therapy because a patient in pain can tell immediately whether or not a pain medication is working and should not be forced to stay on medicine that does not relieve their pain. Chronic pain advocacy groups, and community and labor organizations support this bill because it will ensure that patients have access to the right treatment at the right time. The American Chronic Pain Association asserts that treatment decisions should rely on the physician's clinical expertise, patient's health history, and the best scientific evidence available, rather than driven by cost. The Community Life Improvement Program adds that applying step therapy protocols rigidly to a pain patient is not in the patient's best interest especially when women are more likely than men to be under-treated for their pain and minorities receive even less quality of care. Labor STAFF ANALYSIS OF ASSEMBLY BILL 1826 (Huffman, Feuer) Page 13 groups, such as the American Federation of State, County and Municipal Employees, point out in support that it is fundamentally unfair to permit patients to suffer unnecessary pain in the hopes that a cheaper drug will be as effective as the medication their physicians actually prescribe and they argue that, in the long run, there is no convincing evidence that step therapy actually even saves money. Health care professional organizations, such as the Association of Northern California Oncologists and California Medical Association, writes in support of this bill, asserting that AB 1826 will remove roadblocks and obstacles that prevent patients with pain from receiving the medically necessary, reasonable, and most appropriate pain management and treatment options prescribed by their physicians, who best understand their patients' health needs. The California Nurses Association states that requiring patients to fail first may cause unnecessary delays in access and subsequently compromise patient care and increase health care costs for employers. Pharmaceutical and biotechnology companies, and related associations, such as the California Healthcare Institute (CHI) and BIOCOM, write in support, stating that the health care provider should have access to a full range of therapeutic options to use as they see fit for that particular patients. CHI states that their member company treatments are only effective when patients have access to them. AstraZeneca asserts that physicians should not have their hands tied with cost containment techniques when it comes to making the best possible decision for the patient. Arguments in opposition The Department of Managed Health Care opposes this bill, stating that step therapy, when used appropriately by providers, should continue to be one of the many effective tools for ensuring the delivery of quality and cost-effective health care services. DMHC also points out that federal health care reform incorporates prescription drugs under its essential benefits requirement, but since there is no guidance from the federal government regarding the scope of these benefits, it is premature to consider AB 1826. STAFF ANALYSIS OF ASSEMBLY BILL 1826 (Huffman, Feuer) Page 14 Many health plans and insurers write in opposition to this bill. America's Health Insurance Plans argues that this bill not only fails to further advance the goals of patient safety and quality of care, but threatens the ability of health plans to ensure their enrollees are prescribed the correct course of treatment in clinically appropriate amounts. The California Association of Health Plans writes in opposition that requiring coverage for any prescribed pill or other medication for pain is highly questionable, particularly when the ability of a plan to encourage safe alternatives is also eliminated. The Association of California Life and Health Insurance Companies points out that providers and patients are already protected under current law, as they may file grievances through the Independent Medical Review System, including through an expedited appeals process if there is an imminent and serious threat to the health of the insured, which includes suffering from serious pain. Health Net asserts that requiring plans and insurers to cover any pain medication prescribed by a provider, without regard to guidelines, will drive up health care costs. Molina Healthcare of California points to a recent article in the Journal of the American Medical Association that called for physicians to be critical of new drugs and pointed out that prescribing generic medication, which have a longer track record compared to new drugs, have safety benefits beyond cost. Pharmacy benefit managers (PBMs), including Medco Health Solutions, Inc., and Express Scripts, Inc., maintain that implementation of a well-designed step therapy program ensures that patients receive appropriate medications in a cost effective manner, while reducing waste, error and unnecessary drug use. PBMs contend that prohibiting the use of this key drug management tool for pain medications will make it more difficult to manage the costs of prescription drugs and increase premiums and copayments for all patients. The California Chamber of Commerce opposes the bill because they say it eliminates current cost controls and unravels consumer protections by eliminating the practice of step therapy, the practice of beginning drug therapy with the most cost-effective and safest medication, and progressing to other more costly or risky medications, as necessary. The California Association of Joint Powers Authorities STAFF ANALYSIS OF ASSEMBLY BILL 1826 (Huffman, Feuer) Page 15 objects to the exemption provided to CalPERS from complying with this bill because it ignores that all local public entities will be forced to absorb the prescription coverage cost increases resulting from this bill. Prior legislation AB 1144 (Price) of 2009 would have required health plans and insurers to report specified information relating to chronic pain medication management requirements for their enrollees or insureds to DMHC and CDI, respectively. Failed passage in the Assembly Appropriations Committee. AB 974 (Gallegos), Chapter 68, Statutes of 1998, prohibits health plans that cover prescription drugs from limiting or excluding coverage for a drug that had previously been approved by the plan. SB 625 (Rosenthal), Chapter 69, Statutes of 1998, requires health plans that cover prescription drugs and that have one or more formularies to publicly disclose, upon request, a copy of the current list of prescription drugs that includes specified information and to maintain an expedited prior authorization process for medically necessary non-formulary prescription drugs, and clarifies the content of the notice, including grievance information, that is required to be sent to an enrollee when a prior authorization request is denied by the plan. AB 1985 (Speier), Chapter 1268, Statutes of 1992, prohibits health plans and insurers that provide coverage for prescription drugs, from limiting or excluding coverage for a drug on the basis that it is prescribed for an off-label use, if specified criteria are met. PRIOR ACTIONS Assembly Health: 11-6 Assembly Appropriations: 12-0 Assembly Floor: 45-26 COMMENTS 1.Bill could require plans and insurers to cover medications in situations that are contrary to established guidelines. As currently written, the bill could require plans and STAFF ANALYSIS OF ASSEMBLY BILL 1826 (Huffman, Feuer) Page 16 insurers to cover any prescribed pain medication. There may be cases where a prescribing physician may have good reason why certain pain medication is necessary for a specific patient. Should the bill be amended to ensure that the physician's intention is clear when they prescribe pain medications in a way that is at odds with established guidelines? 2.Is the exemption for CalPERS appropriate? This bill is intended to address barriers that patients in pain may face while trying to access pain medication. However, there is nothing to suggest that enrollees and insureds in CalPERS plans and policies would not be similarly affected. POSITIONS Support: For Grace (sponsor) American Academy of Pain Medicine American Chronic Pain Association American Federation of State, County and Municipal Employees, AFL-CIO American Pain Foundation Arthritis Care Center, Inc. Arthritis Foundation Association of California Neurologists Association of Northern California Oncologists AstraZeneca Bay Area Women's Health Advocacy Council BIOCOM California Academy of Pain Medicine California Academy of Physician Assistants California Alliance for Retired Americans California Conference Board of the Amalgamated Transit Union California Conference of Machinists California Healthcare Institute California Medical Association California NeuroAlliance California Nurses Association California Orthopedic Association California Professional Firefighters California Society of Dermatology and Dermatologic Surgery Community Life Improvement Program Congress of California Seniors STAFF ANALYSIS OF ASSEMBLY BILL 1826 (Huffman, Feuer) Page 17 Consumer Attorneys of California Consumer Federation of California Engineers and Scientists of California, IFPTE Local 20 Familia Unida Living with Multiple Sclerosis Foundation for Peripheral Neuropathy Global Healthy Living Foundation Healthy African American Families International Longshore and Warehouse Union Intractable Pain Patients United Jockeys' Guild Latina Breast Cancer Agency Marin County Pharmaceutical Association (MCPhA) Medical Oncology Association of Southern California (MOSAC) Metropolitan Pain Management Consultants, Inc. National Kidney Foundation National Multiple Sclerosis Society Osteopathic Physicians and Surgeons Pharmacists Planning Service, Inc. (PPSI) Power of Pain Foundation Professional and Technical Engineers, IFPTE Local 21 Southern California Cancer Pain Initiative United Food and Commercial Workers Region 8 States Council UNITE-HERE United Leukodystrophy Foundation 12 individuals Oppose: America's Health Insurance Plans (AHIP) Anthem Blue Cross Association of California Life and Health Insurance Companies Blue Shield of California California Association of Health Plans California Association of Joint Powers Authorities (CAJPA) California Chamber of Commerce (CalChamber) Community Health Group CSAC Excess Insurance Authority Department of Managed Health Care Express Scripts, Inc. Health Net Medco Health Solutions, Inc. STAFF ANALYSIS OF ASSEMBLY BILL 1826 (Huffman, Feuer) Page 18 Molina Health Cares -- END --