BILL ANALYSIS Ó SB 703 Page 1 Date of Hearing: July 5, 2011 ASSEMBLY COMMITTEE ON HEALTH William W. Monning, Chair SB 703 (Ed Hernandez) - As Amended: June 28, 2011 SENATE VOTE : 25-14 SUBJECT : Health care coverage: Basic Health Program. SUMMARY : Creates the Basic Health Plan (BHP), administered by the Managed Risk Medical Insurance Board (MRMIB), which will serve individuals with income up to 200% of the federal poverty level (FPL) who would otherwise be eligible for subsidies in the California Health Benefit Exchange (Exchange). Specifically, this bill : 1)States legislative intent to establish a BHP to implement the option contained in the federal Patient Protection and Affordable Care Act (PPACA). Finds and declares that the BHP: a) Requires eligible individuals and their dependents enrolled in the BHP to be provided a health plan containing essential health benefits (EHBs) at a monthly premium price that does not exceed the amount of the premium that the eligible individual would have been required to pay if the individual had enrolled in the applicable second lowest cost silver plan offered to the individual through the Exchange. b) Prohibits the cost sharing an eligible individual is required to pay under the BHP from exceeding the cost sharing required under a platinum plan for individuals with a household income at or below 150% FPL for the size of the family involved. c) Prohibits the cost sharing an eligible individual is required to pay under the BHP from exceeding the cost sharing required under a gold plan for an individual with a household income above 150% FPL but at or below 200% FPL for the size of the family involved. d) Requires the medical loss ratio for coverage products in the BHP to be 85%, instead of 80% as required for products in the individual and small group market. 2)Defines "health plan" as a private health insurer holding a valid outstanding certificate of authority from the California Department of Insurance (CDI) or a health care service plan SB 703 Page 2 licensed by the Department of Managed Health Care (DMHC). 3)Requires MRMIB to enter into a contract with the United States Secretary of the Department of Health and Human Services (DHHS) to implement the BHP to provide coverage to eligible individuals and permits enrollment on January 1, 2014. 4)Requires MRMIB to administer BHP in conjunction with the Healthy Families Program (HFP), and to provide an eligibility and enrollment process that allows an individual, or his or her natural or adoptive parent, legal guardian, caretaker relative, foster parent, or stepparent with whom the child resides, to enroll in the BHP at the same time an individual, or his or her natural or adoptive parent, legal guardian, caretaker relative, foster parent, or stepparent with whom the child resides, applies for enrollment in HFP for the child. Permits an individual to enroll in the same health plan, or a different health plan, than his or her child or children who are enrolled in HFP. 5)Provides MRMIB authority to take actions in conjunction with administering the BHP, including the following: a) Determine eligibility criteria, requirements for coverage and health plan participation, premiums, and cost-sharing amounts; b) Collect premiums and provide or make available subsidized coverage through participating health plans; c) Provide for the processing of applications and enrollment of eligible individuals; d) Determine and approve the benefit designs and cost sharing required by health plans; e) Maintain enrollment and expenditures to ensure that expenditures do not exceed amounts available in the fund, and, if sufficient funds are not available to cover the estimated cost of program expenditures, requires MRMIB to institute appropriate measures to reduce costs; f) Issue rules and regulations, and until January 1, 2016, provide emergency regulation authority; and, g) Make application assistance payments to individuals who have successfully completed the requirements of a Certified Application Assistant in HFP and who successfully enroll eligible individuals in BHP. 6)Authorizes MRMIB to determine benefits, if any, to offer BHP participants that are in addition to the EHB packages required SB 703 Page 3 by PPACA, including benefits provided through specialized health care service plans and specialized health insurance policies, to the extent PPACA authorizes the inclusion of such plans or policies in the BHP. 7)Requires MRMIB, in conjunction with state Department of Health Care Services (DHCS), to conduct a community outreach and education campaign to assist in notifying eligible individuals of the availability of coverage through BHP. 8)Requires DHCS and the Exchange to include information on the availability of coverage through the BHP in all eligibility outreach efforts, and MRMIB to also include information on the availability of coverage in the Medi-Cal Program and Exchange. 9)Requires MRMIB to ensure that written enrollment information issued or provided, and telephone services provided, by the BHP are available to program subscribers and applicants in each of the Medi-Cal threshold languages. 10)Requires MRMIB to ensure that subscribers are provided information within provider network directories of available linguistically diverse providers, and participating health plans, specialized health plans and specialized insurance policies, provided documentation on how linguistically and culturally appropriate services are provided, including marketing materials, to subscribers. 11)Requires MRMIB to contract with a broad range of health plans in an area, if available, to ensure that subscribers have a choice of health plans from among a reasonable number and different types of competing health plans. 12)Requires MRMIB to take all reasonable steps to ensure that the range of choices of health plans available to each applicant includes health plans that include in their provider networks, and have signed contracts with, traditional and public and private safety net providers. 13)Requires a participating health plan to annually submit to MRMIB a report summarizing its provider network, including information on geographic access for subscribers, linguistic services, the ethnic composition of providers, the number of subscribers who selected traditional and public and private safety net providers. SB 703 Page 4 14)Prohibits MRMIB from relying solely on a determination by DMHC and the CDI of a health plan network's adequacy or geographic access to providers in the awarding of contracts under this bill. 15)Requires MRMIB to collect and review demographic census, and other data to provide to prospective local initiatives, health plans, or specialized health plans, and identify specific provider contracting target areas with significant numbers of uninsured individuals with incomes that would make them eligible for the BHP. 16)Requires MRMIB to give priority to those health plans, on a county-by-county basis, that demonstrate that they have included in their prospective plan networks significant numbers of providers in these geographic target areas. 17)Requires MRMIB to designate a community provider plan (CPP) in each geographic area that is the participating health plan that has the highest percentage of traditional and public and private safety net providers in its network. Requires that subscribers selecting such a health plan be given a premium discount in an amount determined by MRMIB. Includes specialized health plans and insurance policies in this provision and provisions 11) through 16) above. 18)Continues enrollment for an eligible individual enrolled in the BHP for a period of 12 months from the month eligibility is established, to the extent permitted by federal law. 19)Authorizes MRMIB to disenroll an eligible individual enrolled in BHP after two consecutive months of nonpayment of premiums, and a reasonable written notice period of not less than 30 days. Authorizes MRMIB to conduct or contract for collection actions. 20)Requires MRMIB to make sure of a simple and easy to understand mail-in and Internet application process, provide for the operation of a toll-free telephone hotline to respond to requests for assistance, maintain an Internet Website, utilize a standardized format for presenting health benefits plan options, as specified, and establish a process to inform individuals who lose eligibility for the BHP of the availability of coverage through Medi-Cal, and the Exchange SB 703 Page 5 and to transmit their eligibility-related information to those programs electronically to facilitate enrollment. 21)Requires MRMIB in the event that MRMIB reasonably expects that the cost of BHP will exceed the available funds, to transfer individuals at their annual redetermination to coverage in the Exchange. EXISTING FEDERAL LAW : 1)Establishes federal PPACA, which among other private market insurance reforms, authorizes states to establish an American Health Benefit Exchange by January 1, 2014, that makes qualified health plans available to qualified individuals and employers. 2)Provides states an option to establish BHP to enter into contracts to offer one or more health plans providing at least EHBs, as specified, to eligible individuals in lieu of offering such coverage in the Exchange. 3)Requires, as part of the BHP, the state to establish to the satisfaction of DHHS, that the amount of the monthly premium an eligible individual is required to pay for coverage under a standard health plan (in BHP) for the individual and the individual's dependents does not exceed the amount of the monthly premium that the eligible individual would have been required to pay if the individual had enrolled in the applicable second lowest cost silver plan, as specified, offered to the individual through an Exchange; that the cost-sharing an eligible individual is required to pay under the standard health plan does not exceed the cost-sharing required under a platinum plan in the case of an eligible individual with household income not in excess of 150% FPL; and, the cost-sharing required under a "gold plan" in the case of an eligible individual with household income between 150% FPL and 200% FPL and the benefits provided under the standard health plans offered through the program covers at least the essential health benefits (EHBs). 4)Defines EHBs to include: ambulatory patient services, emergency services, hospitalization, maternity and newborn care, mental health and substance use disorder services, including behavioral health treatment, prescription drugs, rehabilitative and habilitative services and devices, laboratory services, preventive and wellness services, chronic SB 703 Page 6 disease management, and pediatric services, including oral and vision care, and requires the Secretary of DHHS to further define EHBs, and ensure that the scope of EHBs is equal to those provided under a typical employer plan. 5)Provides for premium assistance credits for the purchase of health insurance in the Exchange. Credits are calculated on a sliding scale capped at 2% of income for those at or above 133% FPL and phasing out at 9.8% for those at 400% FPL. The premium credit is based on the second lowest-cost silver plan. 6)Provides assistance based on standard out-of-pocket (OOP) limits of $5,950 for individuals and $11,900 for families. Limit is reduced to one-third for those with income between 100% and 200% FPL, to one-half for those with income between 200 and 300% FPL and two-thirds for those with income between 300 and 400% FPL. EXISTING STATE LAW : 1)Establishes HFP, administered by MRMIB, to provide health coverage through health plans to eligible children in families with income up to 250% FPL. 2)Establishes the CPP in HFP, whereby in each geographic area, MRMIB designates a CPP that is the participating health plan which has the highest percentage of traditional and safety net providers in its network. Requires subscribers selecting such a plan to be given a family contribution discount. Pursuant to regulation, traditional and safety net providers are determined by MRMIB for each county based on providers participating in the Child Health and Disability Prevention Program, outpatient hospital based clinics, Federally Qualified Health Centers (FQHCs), rural, community and free clinics participating in the Medi-Cal Program, and specified public and private hospitals participating in the Medi-Cal Program such as county hospitals, non-profit community hospitals, hospitals operated by the University of California, and designated children's hospitals. 3)Authorizes MRMIB to pay designated individuals or organizations an application assistance fee, if the individual or organization assists an applicant to complete the HFP application, and the applicant is enrolled in HFP as a result of the application. SB 703 Page 7 4)Provides for the licensure of health plans, through the DMHC, under the Knox-Keene Health Care Service Plan Act of 1975, and for the licensure of health insurers, through the CDI, under the Insurance Code. 5)Provides for the DHCS, which administers the Medi-Cal Program, a health care services and coverage program for low-income families, pregnant women, children, individuals with disabilities, the elderly, and individuals in long-term care. 6)Establishes the Exchange in state government, and specifies the duty and authority of the Exchange. Requires the Exchange to determine the minimum requirements health plans must meet for participation in the Exchange, the standards and criteria for selecting health plans to be offered in the Exchange, to provide, in each region of the state, a choice of qualified plans, at each of the five levels of coverage contained in federal law (platinum, gold, silver, bronze, and catastrophic). FISCAL EFFECT : According to the Senate Appropriations Committee: Fiscal Impact (in thousands) Major Provisions 2011-12 2012-13 2013-14 Fund Start-up funding: unknown, likely in the millions of dollars annually General* Ongoing cost to operate BHP: likely in the billions of dollars annually Federal/** Private *Permits a General Fund (GF) loan to be repaid by July 1, 2016, with interest. **BHP funded by federal funds and subscriber premiums. COMMENTS : 1)PURPOSE OF THIS BILL . According to the author, this bill will create affordable health care coverage for hundreds of thousands of people without asking for a single dime more from California's taxpayers. The BHP will provide low-income Californians with equal or better benefit levels, less expensive health plan premiums, and lower cost-sharing than SB 703 Page 8 would be available to them in the Exchange using exclusively federal dollars, according to a Mercer Government Human Services Consulting (Mercer) financial feasibility analysis. Adopting the BHP option will lead to more individuals receiving health care coverage as a result of lower premiums, greater ability to access health care because of the lower cost-sharing, increased compliance with the federal individual mandate, and a reduction in uncompensated care for health care providers. Because federal BHP financing is based on the amount spent on premium tax credit and cost-sharing subsidies for commercial Exchange products, the BHP also provides an opportunity to increase funding to certain health plans and providers to amounts that would exceed rates paid to health plans and health care providers through Medi-Cal. The Mercer feasibility analysis estimates rates paid to providers in the BHP would be 20% to 25% higher than Medi-Cal rates, which will improve the financial viability of safety net providers who will continue to serve the remaining uninsured after full implementation of federal health care reform. The BHP option also provides participants with a product with a higher medical loss ratio (85% instead of 80%) than in the Exchange, which allows consumers to get more value out of their premium dollar. Finally, establishing a BHP could also reduce state GF Medi-Cal costs by making it more likely that individuals who qualify for share-of-cost Medi-Cal, because they incur medical costs significant enough to enable them to "spend down" to Medi-Cal eligibility, will shift to the federally-funded BHP. 2)FEDERAL HEALTH CARE REFORM . On March 23, 2010, President Obama signed the PPACA (Public Law ÝPL] 111-148), which was amended on March 30, 2010 by the Health Care and Education Reconciliation Act of 2010 (PL 111-152), together these laws are referred to as PPACA. The law includes many provisions including a restructuring of the small and individual group insurance market, setting minimum standards for health care coverage, providing financial assistance to certain individuals and small employers, and enabling and supporting states to establish Health Benefit Exchanges where individuals and small business can shop for insurance and premium credits and cost sharing subsidies will be determined. 3)BENEFIT CATEGORIES . PPACA establishes five benefit categories-bronze, silver, gold, platinum, and catastrophic - all of which will have the EHB package. Policies cannot be SB 703 Page 9 sold in the small-group and individual market or Exchanges that do not meet the actuarial standards (percentage of medical expense paid by insurer) for the benefit categories established by PPACA. All carriers selling in the individual and small-group markets are at least required to offer silver and gold plans. a) The bronze package will represent minimum creditable coverage with an actuarial value of 60% (i.e., covering 60% of enrollees' medical costs) with out-of-pocket spending limited to that which is defined for health savings accounts (HSAs), or $5,950 for individual policies and $11,900 for family policies. b) The silver benefit package will have an actuarial value of 70% and the same out-of-pocket limits. c) The gold package will have an actuarial value of 80% and the same out-of-pocket limits. d) The platinum package will cover 90% of costs with the same out-of-pocket limits. e) A catastrophic benefit package can be made available for adults younger than age 30, similar to HSA-eligible, high-deductible plans, with the EHB package, the cost of preventive services will be excluded from the deductible as under current HSA law, three primary care visits, and cost-sharing to HSA out-of-pocket limits. 1)PREMIUM TAX CREDITS AND SUBSIDIES . Depending upon income, PPACA provides premium tax credits, lower cost-sharing and lower maximum out-of-pocket (OOP) limits. Beginning 2014, advanceable, refundable tax credits will be available in the Exchange. Tax credits are based on the premium for the second lowest cost silver plan in an Exchange in the area where the person is eligible for coverage. Premiums are capped on a sliding scale depending upon income: a person with income up to 133% FPL has a cap of 2% of their income; a person with income up to 200% FPL has a cap of 6.3%; and, a person with income up to 400% FPL has a cap of 9.5%. As an example, a person with income at 200% FPL ($21,780 in 2011) would have a premium cap of $1,372 (6.3% of income), so if the second lowest cost silver plan premium was $4,000, there would be a premium credit of $2,628 (the difference between the $4,000 premium and the $1,372 cap). Credits are based on annual income. A year-end reconciliation through the Internal Revenue Service could result in a refund to the enrollee or repayment up to a maximum safe harbor of $300 for an individual and $600 for a family at or below 200% FPL, and a SB 703 Page 10 scaled repayment for those with incomes up to 500% FPL. People who qualify for premium credits and are enrolled in an Exchange silver level plan will also be eligible for assistance with cost-sharing requirements. In addition to the maximum OOP caps ($5,950 per individual and $11,900 per family), cost-sharing subsidies will further reduce OOP maximums by two-thirds for income between 100 and 200% FPL; by one-half for income between 200 and 300% FPL; and, by one-third for income between 300 and 400% FPL. 2)BHP . PPACA allows states to establish a BHP to support coverage of low-income individuals not eligible for Medicaid (Medi-Cal in California). BHP eligible individuals are people with income under 200% FPL who would otherwise be eligible for premium credits in the Exchange. Under the BHP, DHHS will transfer to the state for each fiscal year for which one or more standard health plans are operating within the state the amount equal to 95% of the premium tax credits, and cost-sharing reductions, that will be provided for the fiscal year to eligible individuals enrolled in the Exchange. States must assure that cost sharing requirements do not exceed those of a platinum Exchange plan (90% actuarial value) for individuals with income under 150% FPL and those of a gold plan (80% actuarial value) for other BHP enrollees. To qualify, enrollees must be U.S citizens or lawfully present immigrants under age 65, have income that does not exceed 200% FPL, not qualified for Medicare, Medicaid, or Children's Health Insurance Program (CHIP), and not offered employer sponsored insurance that meets PPACA standards for affordability and comprehensiveness. The University California Los Angeles (UCLA) Center for Health Policy Research estimates there are approximately 829,000 individuals in California who would be eligible for BHP, including 46,000 legal immigrants. 3)BHP FEASIBILITY . At the request of the California HealthCare Foundation, Mercer assessed the financial feasibility of the BHP option in terms of whether the BHP could potentially be implemented in California at existing Medi-Cal managed care payment rates. The results indicate that California may be able to implement BHP at no cost to the state GF. Mercer estimates that the average 2014 federal BHP monthly subsidy would be between $441 and $497 per member per month (PMPM). Using conservative estimates, Mercer estimates the average SB 703 Page 11 monthly BHP premium cost to be between $294 and $353 PMPM. Mercer acknowledges that these estimates are speculative and that there are many provisions and details of PPACA that are still unknown. Another report by the Institute for Health Policy Solutions (IHPS) points out that the federal subsidy amounts are highly sensitive to the benchmark plan in the Exchange and that IHPS and the Congressional Budget Office have estimated a lower premium amount ($392 PMPM), which means federal funding available for BHP could be hundreds of millions of dollars less than is assumed by estimates to date (i.e., Mercer). 4)IMPACT ON CONSUMERS . If the BHP uses Medi-Cal providers and plans, it could provide continuity for populations switching between Medi-Cal and the BHP. It could also provide coverage at a lower cost than Exchange coverage, assuming Medi-Cal provider rates. Savings would be passed on to BHP enrollees in the form of lower premiums, cost-sharing, or additional benefits. BHP enrollees would not be subject to year-end reconciliation. To the extent that HFP plans participate, parents and their children could enroll in the same plan. On the other hand, BHP enrollees would not be able to enroll in the Exchange, may be limited in their choice of mainstream health plans, and would not be eligible for tax credits. In addition, there may still be disruption in coverage as income fluctuates (at slightly higher income levels) and people move between BHP and the Exchange. 5)IMPACT ON SAFETY NET . Traditional and safety net providers are those providers who typically serve Medi-Cal, low-income, and uninsured patients. They include public hospitals and primary care clinics, including FQHCs. California, through its Medi-Cal Managed Care Program has three models of managed care delivery; two of those models, Local Initiatives and County Organized Health Systems have networks that include and in some cases are required to include traditional and safety net providers. The BHP, as contemplated in this bill, creates discount premiums for a plan designated a CPP, which obtains that designation based on the percentage of traditional and safety net providers in its network. To the extent the BHP preserves a patient base and revenue stream for traditional and safety net providers, those providers will benefit. FQHCs, however, are not guaranteed higher Prospective Payment System (PPS) rates as they are in Medi-Cal and the Exchange, and may be disadvantaged. Because of SB 703 Page 12 historically low reimbursement rates, provider access and financial solvency is a concern in Medi-Cal and may be a factor in the ability of Medi-Cal plans and providers to compete in the Exchange, but may not be an issue in BHP. 6)IMPACT ON EXCHANGE . Mercer estimates approximately 1.8 million would enroll in the Exchange (even with a BHP). Mercer suggests that the BHP population could represent a less healthy (and more costly) risk profile than the remaining Exchange population above 200% FPL because people with lower incomes tend to have more health issues. The level of premiums and cost-sharing in BHP and in the Exchange will have a direct impact on the risk of the population that enrolls in either place. Higher premium and cost-sharing levels increase the level of adverse risk and lead to higher enrolled population risk, because only those people who really need coverage will be willing to pay for it, especially at higher premium and cost-sharing levels. Lower premiums and cost-sharing levels, as would be offered in the BHP as compared to what the same population would get in the Exchange, could result in better risk in BHP because lower income people with more health issues would not be in the Exchange risk pool. Mercer indicates that plan participation, consumer choice, and risk dynamics for the Exchange population are complicated and beyond the scope of their analysis. The IHPS report indicates that the BHP would substantially reduce the size of the Exchange's core tax credit population by more than half. IHPS uses estimates developed by the Urban Institute that indicate that there are over 2.3 million Californians with income up to 400% FPL, and a half of them have income under 200% FPL and would be eligible for BHP. IHPS states that this reduction in the Exchange population would greatly diminish the Exchange's ability to attract and offer high-value health plans that would compete for three out of four individual market purchasers. Based on the 2009 California Health Interview Survey, a chart prepared by the UCLA Center for Health Policy Research indicates in the potential BHP eligible population 67% self-report their health status as good or better, and 33% indicate they have a chronic condition (any physical or mental condition that limits daily activities). This compare to the 87% of the potential Exchange eligible population who self-report their health status as good or better, and 20% SB 703 Page 13 indicate they have a chronic condition. 7)SUPPORT . The California Association of Health Insuring Organizations (CAHIO) believes BHP is a better option compared to the Exchange because it can offer a more affordable benefit than the Exchange. CAHIO identifies many advantages to establishing BHP as an extension of HFP, such as, MRMIB already has a competitive health plan selection process, appropriate plan oversight, it would reduce administrative start-up expenses, and could maintain the family unit as existing HFP plans are more likely to participate in BHP. The Local Health Plans of California (LHPC) supports the BHP because LHPC believes it will offer a better benefit at lower cost to low-income working families, the BHP will provide continuity and convenience of unified care for parents and children who are in HFP, it will allow safety net providers and their health plan networks to preserve their patient base and revenue streams, and the BHP has the potential to raise the level of compensation for those providers participating in HFP and provide a more sustainable funding base. 8)SUPPORT IF AMENDED . The California Primary Care Association requests amendments to ensure that FQHCs receive PPS reimbursement in the BHP. The Western Center on Law and Poverty (Western Center) supports this bill because they believe, based on the Mercer study, that premiums and cost sharing for this low-income group will be much lower than it would be in the Exchange. However, Western Center believes the BHP should be administered by DHCS or the Exchange in order to provide seamless transitions for this population with volatile income. The Service Employee International Union requests amendments to house the BHP in the Exchange and address adverse selection scenarios that could make the Exchange or BHP pool unsustainable. 9)SEEKS AMENDMENTS . Health Access California has a strong policy preference that BHP be operated by the Exchange. Maternal and Child Health Access (MCH) requests an amendment that this bill "shall not diminish the right of a woman to pregnancy-related care under the Medi-Cal Program under Welfare and Institutions Code sections 14132(u) and 14134.5." MCH wants to preserve pregnancy related benefits and protections on cost-sharing and due process for women with income up to 200% FPL who qualify for Medi-Cal pregnancy services. MCH raises questions about whether these women SB 703 Page 14 would be eligible for BHP for non-pregnancy services and if so, questions, how the programs would coordinate. The American Federation of State, County and Municipal Employees, AFL-CIO (AFSCME) seeks amendments to put BHP in the Exchange. AFSCME believes the Exchange will be undermined and have less bargaining power without the BHP population, covering some, but not all parents of HFP children further complicates things, and that MRMIB has privatized (enrollment) providing poor customer service. 10)OPPOSITION . The California Right to Life Committee opposes any health care program that includes abortion and family planning services with tax payer dollars, and any health care programs that would include minors who could obtain these services without parental notification or consent. The Orange County Board of Supervisors thinks that as many individuals and groups as possible should be served in a competitive, private sector market and that government programs should focus on serving our lowest income individuals who would otherwise be unable to secure coverage. 11)POLICY QUESTIONS . a) Should the impacts of pulling a significant federal subsidy population out of the Exchange to create a separate health coverage program be measured and monitored over time? Mercer, Urban Institute, IHPS and others have anticipated some of the potential impacts of creating a BHP on the Exchange but there is no certainty in any of those studies. Should California create a BHP it may be useful to conduct an evaluation over a period of time after the program has experience with enrollment, plan participation, federal subsidies, etc., to determine the long-term viability of the program and impact on the Exchange. A sunset of the program could accompany the evaluation to give policymakers an opportunity to revisit the utility of the BHP. b) Is MRMIB the best entity to administer the BHP? While MRMIB has demonstrated many accomplishments establishing and operating health coverage programs, there are potentially greater advantages to locating the BHP at either DHCS or the Exchange. At present, there is uncertainty about the future of the HFP. A recent proposal by the Governor would have transferred HFP to Medi-Cal to SB 703 Page 15 be operated as a Medi-Cal expansion. In addition federal authorization of CHIP is time limited. There may be advantages in leveraging purchasing power of the Medi-Cal program or selective contracting of the Exchange that should be taken into consideration. c) Is there urgency to making a policy decision about the BHP at this time? Federal rules are expected on the BHP this fall which may help California evaluate with more confidence the tradeoffs associated with implementing a BHP. REGISTERED SUPPORT / OPPOSITION : Support Local Health Plans of California (sponsor) California Association of Health Insuring Organizations California Association of Public Hospitals and Health Systems California Chiropractic Association Congress of California Seniors Disability Rights Legal Center Molina Healthcare of California Planned Parenthood Affiliates of California Santa Clara County Opposition American Federation of State, County and Municipal Employees, AFL-CIO California Right to Life Committee, Inc. Orange County Board of Supervisors Analysis Prepared by : Teri Boughton / HEALTH / (916) 319-2097