BILL ANALYSIS                                                                                                                                                                                                    

                                                                  SB 946
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          Date of Hearing:  September 7, 2011

                            ASSEMBLY COMMITTEE ON HEALTH
                              William W. Monning, Chair
                 SB 946 (Steinberg) - As Amended:  September 6, 2011

           SENATE VOTE  :  Not applicable
          SUBJECT  :  Health care coverage: mental illness: pervasive 
          developmental disorder or autism: public health

           SUMMARY  :  Requires health plans and health insurance policies to 
          cover behavioral health therapy (BHT) for pervasive 
          developmental disorder or autism (PDD/A), requires plans and 
          insurers to maintain adequate networks of autism service 
          providers, establishes an Autism Advisory Task Force (Task 
          Force) in the Department of Managed Health Care (DMHC), sunsets 
          this bill's autism mandate provisions on July 1, 2014, and makes 
          other technical changes to existing law regarding HIV reporting 
          and mental health services payments.  Specifically,  this bill  :  

          1)Requires every health plan contract that provides hospital, 
            medical, or surgical coverage and health insurance policy 
            issued, amended, or renewed on or after July 1, 2012, pursuant 
            to California's mental health parity law, to provide coverage 
            for BHT for PDD/A.  

          2)Requires the coverage to be provided in the same manner and to 
            be subject to the same requirements as provided in 
            California's mental health parity law.

          3)Provides, notwithstanding 1) above, as of the date that 
            proposed final rulemaking for essential health benefits (EHBs) 
            is issued, that this bill does not require any benefits to be 
            provided that exceed the EHBs that all health plans will be 
            required by federal regulations to provide under the federal 
            Patient Protection and Affordable Care and Education 
            Reconciliation Act of 2010 (PPACA), as amended by the federal 
            Health Care and Education Reconciliation Act of 2010.

          4)Precludes this bill from affecting developmentally disabled 
            and early intervention services for which an individual is 
            eligible, as specified.

          5)Precludes this bill from affecting or reducing any obligation 


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            to provide services under an individualized education program, 
            an individualized service plan, or under the Individuals with 
            Disabilities Education Act and its implementing regulations, 
            as specified.

          6)Requires every health plan and insurer subject to this bill to 
            maintain an adequate network that includes qualified autism 
            service providers who supervise and employ qualified autism 
            service professionals or paraprofessionals who provide and 
            administer BHT.  Permits health plans and insurers to 
            selectively contract with providers within these requirements.

          7)Defines "PDD/A" as the same meaning in California's mental 
            health parity law.

          8)Defines "BHT" as professional services and treatment programs, 
            including applied behavior analysis (ABA) and other behavior 
            intervention programs, that develop or restore, to the maximum 
            extent practicable, the functioning of an individual with 
            PDD/A and that meet the following:
             a)   Is prescribed by a licensed California physician and 
               surgeon, or psychologist;
             b)   Is provided under a treatment plan prescribed by a 
               qualified autism service provider and administered by one 
               of the following: 
               i)     A qualified autism service provider;
               ii)    A qualified autism service professional supervised 
                 and employed by the qualified autism service provider; 
               iii)   A qualified autism service paraprofessional 
                 supervised and employed by a qualified autism service 
                 provider; and,
             c)   The treatment plan, which must be reviewed no less than 
               once every six months, as specified, has measurable goals 
               over a specific timeline that is developed and approved by 
               the qualified autism service provider for the specific 
               patient being treated.  

          9)Defines a "qualified autism service provider" as either of the 
             a)   A person, entity, or group that is certified by a 
               national entity, such as, but not limited to, the Behavior 
               Analyst Certification Board, that is accredited by the 
               National Commission for Certifying Agencies, and who 
               designs, supervises, or provides treatment for PDD/A, 


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               provided the services are within the experience and 
               competence of the person, entity, or group that is 
               nationally certified; or,
             b)   A person or entity licensed as a physician and surgeon, 
               physical therapist, occupational therapist, psychologist, 
               marriage and family therapist, educational psychologist, 
               clinical social worker, professional clinical counselor, 
               speech-language pathologist, or audiologist who designs, 
               supervises, or provides treatment for PDD/A, provided the 
               services are within the experience and competence of the 

          10)Defines a "qualified autism service professional" as an 
            individual who provides behavioral health treatment, is 
            employed and supervised by a qualified autism service 
            provider, provides treatment pursuant to a treatment plan 
            developed and approved by the qualified autism service 
            provider, is a behavioral service provider approved as a 
            vendor by a California regional center to provide services as 
            an Associate Behavior Analyst, Behavior Analyst, Behavior 
            Management Program, and has training and experience in 
            providing services for PDD/A, as specified.

          11)Defines a "qualified autism service paraprofessional" as an 
            unlicensed and uncertified individual who is supervised and 
            employed by a qualified autism service provider, provides 
            treatment and implements services pursuant to a treatment 
            plan, meets the criteria set forth in regulations, as 
            specified, and has adequate education, training and 
            experience, as certified by a qualified autism service 

          12)Requires DMHC, in consultation with the California Department 
            of Insurance (CDI), to convene a Task Force by February 1, 
            2012, in collaboration with other agencies, departments, 
            advocates, autism experts, health plan representatives, other 
            entities, and stakeholders that it deems appropriate.  
            Requires the Task Force to develop recommendations regarding 
            BHT that are medically necessary for the treatment of 
            individuals with autism or pervasive developmental disorder, 
            and at least the following:
             a)   Interventions that have been scientifically validated 
               and have demonstrated clinical efficacy; 
             b)   Interventions that have measurable treatment outcomes;
             c)   Patient selection, monitoring, and duration of therapy;


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             d)   Qualifications, training and supervision of providers; 
             e)   Adequate networks of providers.

          13)Requires the Task Force to also develop recommendations 
            regarding the education, training and experience requirements 
            that unlicensed individuals providing autism services must 
            meet to secure a license from the State.

          14)Requires DMHC to submit a report of the Task Force to the 
            Governor, President pro Tem of the Senate, the Speaker of the 
            Assembly, and the Senate and Assembly Committees on Health by 
            December 31, 2012, on which date the Task Force ceases to 

          15)Exempts from this bill a specialized health plan or health 
            insurance policy that does not deliver mental health or 
            behavioral health services to enrollees, or an accident only, 
            specified disease, hospital indemnity, or Medicare supplement 
            policy, a health plan contract or health insurance policy 
            under Medi-Cal or Healthy Families, and a health care benefit 
            plan or contract pursuant to the Public Employees' Retirement 

          16)Provides that nothing in this bill be construed to limit the 
            obligation to provide services under California's mental 
            health parity law.

          17)Permits, notwithstanding any other provision of law, a health 
            plan or health insurer to utilize case management, network 
            providers, utilization review techniques, prior authorization, 
            copayments, or other cost sharing.

          18)Defines, for the purposes of Insurance Code provisions of 
            this bill, "provider,"
           "professional provider," "network provider," "mental health 
            provider," and "mental health professional" to include the 
            term "qualified autism service provider" as defined.

          19)Sunsets the provisions of this bill on July 1, 2014.
          Provisions already analyzed

           20)Authorizes the Department of Public Health to develop a form 
            to be used to report cases of HIV infection to the local 


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            health department and permits the form to be implemented 
            without promulgating new regulations.

          21)Conforms state law to existing federal regulations and 
            current practice of the Department of Mental Health (DMH) with 
            regard to negotiated rates and incentive payments for the 
            provision of Medi-Cal reimbursable community mental health 
          EXISTING LAW  :  

          1)Enacts, in federal law, the PPACA to, among other things, make 
            statutory changes affecting the regulation of, and payment 
            for, certain types of private health insurance.  Includes the 
            definition of EHBs that all qualified health plans must cover, 
            at a minimum, with some exceptions.

          2)Provides that the EHB package in 1) above will be determined 
            by the federal Department of Health and Human Services (HHS) 
            Secretary and must include, at a minimum, ambulatory patient 
            services; emergency services; hospitalizations; mental health 
            and substance abuse disorder services, including behavioral 
            health; prescription drugs; and, rehabilitative and 
            habilitative services and devices, among other things.

          3)Establishes the Knox-Keene Health Care Service Plan Act of 
            1975 (Knox-Keene) to regulate and license health plans and 
            specialized health plans by the DMHC and provides for the 
            regulation of health insurers by the CDI.

          4)Requires every health plan contract or health insurance policy 
            issued, amended, or renewed on or after July 1, 2000, that 
            provides hospital, medical, or surgical coverage to provide 
            coverage for the diagnosis and medically necessary treatment 
            of severe mental illness (SMI) of a person of any age, and of 
            serious emotional disturbances of a child, under the same 
            terms and conditions applied to other medical conditions, as 

          5)Establishes the California Legislative Blue Ribbon Commission 
            on Autism, until November 30, 2008, to study and investigate 
            the early identification and intervention of Autism Spectrum 
            Disorders (ASDs), gaps in programs and services available to 
            those with ASDs, and to make recommendations to address gaps 
            in services.


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          6)Requires the Department of Developmental Services (DDS) to 
            develop procedures for the diagnosis of ASDs.

           FISCAL EFFECT  :  This bill has not yet been analyzed by a fiscal 

           COMMENTS :

           1)PURPOSE OF THIS BILL  .  According to the author, the intent of 
            this legislation is to ensure that therapeutic decisions for 
            the medical treatment of ASD remain in the hands of physicians 
            and other appropriate medical professionals.  ASD is the 
            fastest-growing serious developmental disability in the U.S.  
            ASD is now more common than childhood cancer, juvenile 
            diabetes, and pediatric AIDS combined. According to the 
            author, although there is no cure for ASD, BHT is now widely 
            accepted as an effective medical treatment for this disorder.  
            Nevertheless many private health plans and health insurance 
            companies deny BHT under the pretext that it is an educational 
            service and therefore  not a covered benefit  .  This 
            administrative decision by the health plans precludes any 
            review by physicians or other medical providers; thereby 
            potentially withholding crucial medical services.  The author 
            believes this bill closes a dangerous loophole in the existing 
            mental health parity law and ensures that healthcare decisions 
            for the treatment of ASD are provided only by the appropriate 
            medical professionals.

          According to the author, current California mental health parity 
            law, AB 88 (Thomson), Chapter 534, Statutes of 1999, requires 
            private health plans and health insurance companies to provide 
            coverage for the medically necessary treatment of ASD.  The 
            author states that this bill establishes a definition and 
            criteria for BHT that are consistent with established "best 
            practices" and medical treatment standards, and that this bill 
            simply requires coverage for BHT services that meet these 
            standards and also establishes appropriate criteria for 
            qualified BHT providers.  The author believes questions of 
            medical necessity, experimental interventions, and other 
            treatment issues will be resolved by the existing independent 
            medical review (IMR) process under DMHC or the CDI.

           2)BHT  .  In discussions surrounding this and other related bills, 
            terminology is used interchangeably to refer to presumably the 


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            same or similar types of therapy for the treatment of PDD/A.  
            The California Health Benefits Review Program (CHBRP) analysis 
            of SB 166 (Steinberg), a bill similar to this bill, refers to 
            intensive behavioral intervention therapy, which CHBRP 
            considers interventions based on ABA and/or other theories of 
            behavior.  State law defines intensive behavioral intervention 
            therapy as any form of ABA that is comprehensive, designed to 
            address all domains of functioning, and provided in multiple 
            settings for no more than 40 hours per week, across all 
            settings, depending on the individual's needs and progress. 
            Interventions can be delivered in a one-to-one ratio or small 
            group format, as appropriate.  The CDI compiled material on 
            the scientific medical literature on the use of BHT/behavioral 
            intervention therapy, including ABA.  This bill refers to BHT 
            as professional services and treatment programs, including ABA 
            and other behavior intervention programs, as specified.  ABA, 
            which is defined in state law as the design, implementation, 
            and evaluation of systematic instructional and environmental 
            modifications to promote positive social behaviors and reduce 
            or ameliorate behaviors which interfere with learning and 
            social interaction, seems to be at the center of coverage 
            disputes, settlements and litigation.  The main question is 
            whether or not ABA is a health care service covered under 
            California's mental health parity law.

           3)PDD/A  .  According to CHBRP, PDD/A includes neurodevelopmental 
            disorders that typically become symptomatic in children aged 
            two to three years, but may not be diagnosed until age five 
            years or older.  CHBRP considers five disorders as PDD/A 
            (Autism, Asperger's Disorder, Pervasive Developmental 
            Disorder, Rett's Disorder and Childhood Disintegrative 
            Disorder).  ASD is also used but sometimes excludes less 
            common disorders that are technically part of PDD/A.

           4)CURRENT PARITY LAW  .  In 1999, the Legislature passed and the 
            Governor signed AB 88 requiring health plans and health 
            insurers to provide coverage for the diagnosis and medically 
            necessary treatment of certain SMIs of a person of any age, 
            and of serious emotional disturbances of a child, as defined, 
            under the same terms and conditions applied to other medical 
            conditions.  Nine specific diagnoses are considered SMI: 
            schizophrenia; schizoaffective disorder; bipolar disorder; 
            major depressive disorder; panic disorder; obsessive 
            compulsive disorder; PDD/A; anorexia nervosa; and, bulimia 
            nervosa.  For covered conditions, health plans are required to 


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            eliminate benefit limits and share-of-cost requirements that 
            have traditionally rendered mental health benefits less 
            comprehensive than physical health coverage.  Current state 
            law requires mental health parity benefits to include 
            outpatient services, inpatient hospital services, partial 
            hospital services, and prescription drugs, if the health plan 
            contract includes coverage for prescription drugs.  Current 
            state regulations require parity coverage for at least, in 
            addition to all basic and other health care services required 
            by Knox-Keene, crisis intervention and stabilization, 
            psychiatric inpatient services, including voluntary inpatient 
            services, and services from licensed mental health providers.

          The federal Mental Health Parity and Addiction Equity Act (MHPA) 
            requires group health insurance plans to cover mental illness, 
            including ASDs, on the same terms and conditions as other 
            illnesses and helps to end discrimination against those who 
            seek treatment for mental illness.  The MHPA does not mandate 
            group health plans provide any mental health coverage.  
            However, if a plan does offer mental health coverage, then it 
            requires equity in financial requirements, such as 
            deductibles, co-payments, coinsurance, and out-of-pocket 
            expenses; equity in treatment limits, such as caps on the 
            frequency or number of visits, limits on days of coverage, or 
            other similar limits on the scope and duration of treatment; 
            and, equality in out-of-network coverage.  The MHPA applies to 
            all group health plans for plan years beginning after October 
            3, 2009, and exempts small firms of 50 or fewer employees.

           5)IMR  .  Individuals covered by health plans or health insurers 
            in California are entitled to an IMR if a health plan or 
            insurer denies health care services or payment for health care 
            services based on medical necessity.  An IMR is a process 
            where expert independent medical professionals are selected to 
            review specific medical decisions made by the plans or 
            insurers.  DMHC and CDI administer the IMR program to enable 
            consumers to request an impartial appraisal of medical 
            decisions within certain guidelines specified in law.  An IMR 
            can only be requested if the plan or insurer's decision 
            involves the medical necessity of a treatment, an experimental 
            or investigational therapy for certain medical conditions, or 
            a claims denial for emergency or urgent medical services.  
            According to CDI, since 2009, 32 behavioral intensive therapy 
            or applied behavioral analysis cases have gone to IMR and 28 
            were overturned.   According to the DMHC, since 2009, 93% of 


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            148 disputes brought to DMHC by consumers, whose health plans 
            have denied some form of autism treatment, have been resolved 
            in favor of the consumer.

           6)EHBs  .  The PPACA requires qualified health plans to cover 
            specified categories of EHBs, including BHT and rehabilitative 
            services, by 2014.  The HHS Secretary is tasked with defining 
            these benefit categories through regulation so that they 
            mirror those benefits offered by a "typical" employer plan.  
            Qualified plans are required to cover EHBs by 2014.  Federal 
            guidance with respect to EHBs is expected later this year and 
            in 2012.  In a January 2011 issue brief by the CHBRP focusing 
            on the federal requirement to cover EHBs, CHBRP notes that 
            there is considerable legal ambiguity over how state mandates 
            requiring the coverage of the treatment for a specific 
            condition or disease will interact with federal law.  CHBRP 
            states that these mandates often extend across multiple 
            benefit categories.  CHBRP cites, as an example, California's 
            mandate to cover breast cancer treatment, which implicitly 
            requires coverage for screening and testing, medically 
            necessary physician services, ambulatory services, 
            prescription drugs, hospitalization, and surgery.  CHBRP 
            writes that it is unclear how California benefit mandates that 
            overlap across several EHB categories would be evaluated in 
            relation to the EHB package.

           7)CHBRP  .  CHBRP was created in response to AB 1996 (Thomson), 
            Chapter 795, Statutes of 2002, which requests the University 
            of California to assess legislation proposing a mandated 
            benefit or service, and prepare a written analysis with 
            relevant data on the public health, medical, and economic 
            impact of proposed health plan and health insurance benefit 
            mandate legislation.  Among CHBRP's findings of their 
            analysis of SB 166 are the following:

              a)   Medical Effectiveness  .  The literature is difficult to 
               synthesize because most studies compared intensive 
               behavioral intervention therapies of differing duration 
               and intensity or compared interventions based on different 
               theories of behavior.  Many of the studies do not assess 
               outcomes over sufficiently long periods of time to 
               determine long-term benefits.  However, CHBRP did 
               determine that the preponderance of evidence from some 
               meta-analyses suggest that intensive behavioral therapy on 
               applied behavioral analysis is more effective than 


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               therapies based on other theories or less intensive 
               therapies in improving adaptive behavior, increasing 
               intelligence quotient, and in improving expressive 

              b)   Utilization, Cost, and Coverage Impacts  .  CHBRP 
               estimates that the postmandate, new benefit coverage would 
               result in a net decrease in expenses for noncovered 
               benefits for an estimated 7,300 enrollees with PDD/A (who 
                                             use intensive behavioral therapies) of about $146 million. 
                CHBRP assumes this postmandate shift would represent a 
               savings for enrollees, their families, charities, DDS, 
               California Department of Education, and other payors.  The 
               extent to which the shift would result in a reduction in 
               financial burden for enrollees with PDD/A (and their 
               families) is unknown.    CHBRP estimates an increase in 
               total expenditures by $93.3 million for the insured 
               population resulting from $222.4 million increase in 
               health insurance premiums, and a $17.1 million increase in 
               out-of-pocket expenses for enrollees with PDD/A with newly 
               covered benefits.

              c)   Public Health Impact  .  CHBRP estimates there could be 
               some improvements to intelligence quotient and adaptive 
               behaviors for children aged 18 months to nine years with 
               diagnoses of PDD/A due to the effectiveness of intensive 
               behavioral intervention therapy and increased benefit 
               coverage on utilization.  The public health impact on 
               persons outside of this age range or with other PDDs is 
               unknown.  CHBRP found no literature or data regarding the 
               possible differential use or outcomes by gender.  The 
               public health impact on reducing potential racial and 
               ethnic disparities of PDD/A symptoms is unknown.  There is 
               an increased risk of premature death associated with 
               PDD/A, but CHBRP found no evidence that intensive 
               behavioral intervention therapies would reduce premature 
               death for the population.

           8)SENATE SELECT COMMITTEE HEARING  .  At a recent hearing of the 
            Senate Select Committee on Autism and Related Disorders held 
            on July 13, 2011, the Commissioner of CDI indicated that CDI 
            believes applied behavioral analysis is a covered benefit 
            under mental health parity.  The DMHC announced settlement 
            agreements at various stages of completion with Blue Shield 
            of California, Anthem Blue Cross and Kaiser in which it is 


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            anticipated that these health plans would agree to cover ABA 
            services to their enrollees through a network of qualified 
            individuals who are either licensed or are supervised by 
            licensed providers.  These settlement agreements are 
            temporary pending the result of litigation or should 
            legislation be enacted on this matter.  At the time of the 
            writing of this analysis two of the three agreements have 
            been reached (Blue Shield of California and Anthem Blue 

           9)LICENSING ISSUES  .  Another aspect of the disputes over ABA is 
            whether or not the individuals who provide ABA are, or should 
            be, licensed.  Blue Shield of California asserts that ABA is 
            not health care services because the treatment is not 
            provided by individuals who are licensed or certified as 
            health care providers, and Blue Shield's contracts expressly 
            exclude coverage for services provided by individuals not 
            licensed or certified by the State.  Behavior analysts, who 
            provide ABA, are typically certified by the Behavior Analyst 
            Certification Board, which is not a government entity.   In a 
            July 2011 press release issued by the DMHC announcing the 
            settlement with Blue Shield of California, the DMHC indicates 
            that it prevailed in the Los Angeles Superior Court challenge 
            by Consumer Watchdog on DMHC's enforcement of the law that 
            ABA must be provided by a licensed health care professional.  
            DMHC also indicates that health plans have reported a 
            shortage of providers with the proper licensure or 
            certification to provide many autism therapies.   AB 1205 was 
            introduced to set up a licensing process for providers who 
            are certified through the Behavior Analyst Certification 
            Board.  According to the policy analysis of AB 1205, there 
            was opposition to AB 1205 due to already strained resources 
            at the Board of Behavioral Sciences, which would have been 
            responsible for licensing behavior analysts.  

           10)SUPPORT  .  According to the author, this bill is sponsored by 
            the Alliance of California Autism Organizations; Autism 
            Speaks; Special Needs Network; The Help Group.  The 
            Association of Regional Center Agencies supports this bill 
            for many reasons including that it will save the state 
            millions of dollars through offsetting regional center funds 
            towards funding autism health-related treatment and services, 
            which could be used to support other segments of the regional 
            center population.


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           11)OPPOSITION  .  The California Association of Health Plans 
            writes in opposition that this bill will increase health 
            premiums by hundreds of million, promises autism benefits 
            that could prove false if the benefits are not included in 
            EHBs, timing is wrong and other mandates were wisely held, 
            government purchasers are exempt, early childhood screening, 
            diagnosis and medical services are already covered by health 
            plans and shifting the responsibility for educational 
            services increases premiums and sets a costly new precedent.

           12)OPPOSE UNLESS AMENDED  .  Consumer Watchdog, which is involved 
            in class action litigation against Blue Cross and Kaiser, as 
            well as individual suits seeking damages for personal 
            injuries, related to wrongful denials, requests amendments.  
            Consumer Watchdog believes provisions in this bill: allow 
            bureaucrats and health insurers to make medical decisions; 
            permit future "proposed" federal regulations to pre-empt 
            state law and open the door for insurers to inappropriately 
            refuse to cover ABA on the grounds that it is educational; 
            undermines access by requiring autism specialists to "employ" 
            providers; and gives insurers an inappropriate shield against 
            several pending civil lawsuits and an enforcement action 
            brought by CDI.  Kaiser Permanente indicates that this bill 
            fails to provide clarity around statutory service provision, 
            excludes millions of children from coverage, and creates 
            increased cost pressures on families and businesses that 
            purchase health coverage, and for these reasons oppose this 
            bill unless it is amended to address their concerns.

           13)RELATED LEGISLATION  .  
             a)   AB 171 (Beall) requires health plans and health insurers 
               to cover the screening, diagnosis, and treatment of ASD.  
               AB 171 is pending in the Assembly Appropriations Committee.
             b)   AB 1205 (Bill Berryhill) requires the Board of 
               Behavioral Sciences to license behavioral analysts and 
               assistant behavioral analysts, on and after January 1, 
               2015, and includes standards for licensure such as 
               specified higher education and training, fieldwork, passage 
               of relevant examinations, and national board accreditation. 
                This bill was held on Suspense in the Assembly 
               Appropriations Committee.
             c)   SB 166 requires health care service plans licensed by 
               DMHC and health insurers licensed by the CDI to provide 
               coverage for BHT for autism.  SB 166 is pending in the 
               Senate Health Committee.


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             d)   SB 770 (Steinberg) requires health plans and health 
               insurance policies to provide coverage for BHT.  SB 770 is 
               pending in the Assembly Appropriations Committee.

             a)   Does the author intend for the mandate provisions of 
               this bill to not be enforced upon the date final proposed 
               PPACA rules are  issued  if the mandate exceeds EHBs as 
               opposed to the effective date of the rules?  This bill's 
               mandate provisions are in effect until July 1, 2014 or as 
               of the date that proposed final rulemaking for EHBs is 
               issued if the coverage under this bill exceeds coverage 
               defined in EHBs.  Should the EHB rules be issued as 
               expected on or before 2012 the mandate provisions in this 
               bill could be undone sooner than the effective date of 
               PPACA.  PPACA requires the provision of EHBs effective 

             b)   Is DMHC the appropriate convener of the Task Force?  The 
               objective of the Task Force appears to be to develop 
               recommendations for a future medical necessity framework 
               for coverage decisions about BHT and recommendations for 
               licensure of behavior analysts.  This bill includes 
               requirements that "other agencies, departments, advocates 
               and stakeholders" collaborate on the Task Force.  The 
               issues presented by this bill and related disputes create 
               an intersection between education, health care, and 
               developmental services, which suggests a broader policy 
               discussion that may rise to a higher level than the DMHC.


          Supervisor Dave Pine, San Mateo County
          Association of Regional Center Agencies 
          The Arc
          United Cerebral Palsy in California
          Association of California Life & Health Insurance Companies
          California Association of Health Plans 
          California Chamber of Commerce


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           Analysis Prepared by  :    Teri Boughton / HEALTH / (916) 319-2097