BILL ANALYSIS                                                                                                                                                                                                    �






                             SENATE COMMITTEE ON HEALTH
                          Senator Ed Hernandez, O.D., Chair

          BILL NO:       AB 50
          AUTHOR:        Pan
          AMENDED:       August 15, 2013
          HEARING DATE:  August 21, 2013
          CONSULTANT:    Bain

           SUBJECT : Medi-Cal: eligibility: pregnancy-related and postpartum  
          services. Urgency
           
          SUMMARY  : Expands the benefit package to Medi-Cal-eligible  
          pregnant women with family incomes under 100 percent of the  
          federal poverty level to full scope Medi-Cal benefits. Permits  
          the Department of Health Care Services to initially implement  
          specified Medi-Cal provisions of the recently enacted AB X1 1  
          (John A. Perez), Chapter 3, Statutes of 2013-14, and SB X1 1  
          (Hernandez and Steinberg), Chapter 4, Statutes of 2013-14, by  
          means of all-county letters, plan letters, plan or provider  
          bulletins, or similar instructions, followed by a requirement  
          that Department of Health Care Services adopt regulations by  
          July 1, 2015. Requires, by January 1, 2015, the CalHEERS  
          application form for Medi-Cal and Covered California coverage,  
          to include questions that are voluntary for applicants to answer  
          on applicant demographics.

          Existing law:
          1.Establishes the Medi-Cal program, which is administered by  
            Department of Health Care Services (DHCS), under which  
            qualified low-income individuals receive health care services.

          2.Requires DHCS to provide Medi-Cal eligibility to pregnant  
            women and infants with family incomes up to 200 percent, of  
            the federal poverty level (FPL). The scope of Medi-Cal  
            benefits provided to pregnant women (full scope benefits  
            versus pregnancy-only benefits) depends upon several factors,  
            including her income, immigration status, assets, and whether  
            she is otherwise Medi-Cal eligible. 
          
          3.Requires DHCS to develop and implement, in consultation with  
            county program and fiscal representatives, a new budgeting  
            methodology for Medi-Cal county administrative costs. Requires  
            the new budgeting methodology be used to reimburse counties  
            for eligibility determinations for applicants and  
            beneficiaries, including one-time eligibility processing and  
                                                         Continued---



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            ongoing case maintenance. Requires DHCS to provide the new  
            budgeting methodology to the legislative fiscal committees by  
            March 1, 2012, and permits inclusion of the methodology in the  
            May 2012 Medi-Cal Local Assistance Estimate for the 2012-13  
            fiscal year and each fiscal year thereafter.

          4.Requires a single, accessible, standardized paper, electronic,  
            and telephone application for insurance affordability programs  
            be developed by DHCS in consultation with the Managed Risk  
            Medical Insurance Board and the Covered California board.  
            Requires the application to be used by all entities authorized  
            to make an eligibility determination for any of the insurance  
            affordability programs and by their agents.

          5.Permits the form to include questions that are voluntary for  
            applicants to answer regarding demographic data categories,  
            including race, ethnicity, primary language, disability  
            status, and other categories recognized by the federal  
            Secretary of Health and Human Services (HHS) under a specified  
            provision of the  Affordable Care Act (ACA).
          
          This bill:
          1.Makes women with income less than 100 percent of the FPL  
            eligible for full scope Medi-Cal benefits under a specified  
            provision of federal and if she meets all other eligibility  
            requirements. Implements this provision only if and to the  
            extent that federal financial participation is available and  
            any necessary federal approvals have been obtained.

          2.Permits DHCS to implement the below-listed provisions of the  
            recently enacted Medi-Cal-related provisions implementing the  
            ACA of AB X1 1 and SB X1 1 by means of all-county letters,  
            plan letters, plan or provider bulletins, or similar  
            instructions until the time any necessary regulations are  
            adopted.  Requires DHCS to adopt regulations by July 1, 2015,  
            in accordance with the requirements of the rulemaking  
            requirements of the Administrative Procedure Act. Requires  
            DHCS to provide a status report to the Legislature on a  
            semiannual basis until regulations have been adopted. 

                  a.        The Medi-Cal expansion to former foster youth  
                    up to age 26;
                  b.        The requirements involving Medi-Cal  
                    eligibility redeterminations and termination of  
                    benefits (known as "SB 87" after the implementing  
                    statute);




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                  c.        The implementation of the adoption of a  
                    different income counting methodology using Modified  
                    Adjusted Gross Income in Medi-Cal, the elimination of  
                    the asset test, the elimination of the deprivation  
                    requirement and the implementation of a specified  
                    ACA-required Medicaid maintenance of effort  
                    eligibility requirement;
                  d.        The provision of Medi-Cal benefits during a  
                    presumptive eligibility period who have been  
                    determined eligible by a qualified hospital in  
                    accordance with a specified provision of federal law  
                    enacted by the ACA;
                  e.        The requirement that DHCS and any other  
                    governmental agencies determining eligibility for, or,  
                    enrollment in Medi-Cal or any other program  
                    administered by DHCS, and Covered California share  
                    information with each other as necessary to perform  
                    their respective statutory and regulatory duties under  
                    state and federal law;
                  f.        The implementation of the benefit and  
                    affordability wrap for legal immigrant adults who are  
                    not eligible for Medi-Cal benefits because of the five  
                    year federal bar;
                  g.        The implementation of the Medi-Cal benefit  
                    package for the Medicaid expansion population; and,
                  h.        The implementation of the new budgeting  
                    methodology for Medi-Cal county administrative costs.

          3.Permits, rather than requires under existing law, the  
            budgeting methodology for county Medi-Cal eligibility  
            determination to include specified costs. Requires the new  
            budgeting methodology to be implemented no sooner than the  
            2015-16 fiscal year, to reflect the impact of ACA  
            implementation on county administrative work, and to be  
            provided to the legislative fiscal committees by March 1 of  
            the fiscal year immediately preceding the first fiscal year of  
            implementation.

          4.Permits, until January 1, 2015, the California Healthcare  
            Eligibility, Enrollment, and Retention System (CalHEERS)  
            application form for Medi-Cal and Covered California coverage  
            to include additional questions that are voluntary for  
            applicants to answer on sexual orientation and gender identity  
            or expression.





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          5.Requires, by January 1, 2015, the CalHEERS application form to  
            include questions that are voluntary for applicants to answer  
            regarding demographic data categories, including race,  
            ethnicity, primary language, disability status, sexual  
            orientation, gender identity or expression and other  
            categories recognized by the federal Secretary of HHS.

          6.Requires the training of "individuals, including county human  
            services staff," (instead of "specialized county employees")  
            in carrying out a DHCS program, to provide information and  
            assistance to Medi-Cal beneficiaries to understand and  
            successfully use the services of Medi-Cal managed care plans.

          7.Makes other clarifying changes to the recently the recently  
            enacted Medi-Cal-related provisions implementing the ACA in AB  
            X1 1 and SB X1 1.

           FISCAL EFFECT  : The current version of this bill has not been  
          analyzed by a fiscal committee.

           PRIOR VOTES  : Not relevant  
           
          COMMENTS  :  
           1.Author's statement. According to the author, AB 50 is needed  
            to supplement AB X1 1 and SB X1 1 by providing DHCS with  
            time-limited authority to use all county letters or similar  
            instructions to implement many of the recent Medi-Cal changes,  
            but requiring the adoption of regulations by a date certain so  
            as to ensure public input, clear program rules and  
            accountability in implementation of the Medi-Cal changes. In  
            addition, this bill would require DHCS to provide full-scope  
            coverage to pregnant women in Medi-Cal to promote women's  
            overall health, well-being and financial security, instead of  
            pregnancy-only coverage for certain women under existing law.  
            AB 50 also requires the CalHEERS application for Medi-Cal and  
            Covered California to ask demographic questions that are  
            voluntary for applicants to answer, beginning in 2015. The  
            author states that, in order to meet the requirements of the  
            ACA and for the new enrollment system to be operational by  
            October 1, 2013, a decision was made to omit these items from  
            the initial system design.  However, the author argues, this  
            demographic information will be crucial and therefore should  
            begin to be collected in the future. The author points out  
            that it will be needed to assess whether outreach and  
            enrollment strategies to target certain populations are  
            needed. This data will also be crucial in identifying and  




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            reducing health disparities. Finally, this bill contains  
            changes to the county budgeting methodology for eligibility  
            determinations agreed to by DHCS and the County Welfare  
            Directors Association.

          2.Medi-Cal benefits for low-income pregnant women. State law  
            requires Medi-Cal to cover pregnant women without a share of  
            cost with incomes below 200 percent of the FPL. However, the  
            scope of coverage a woman receives (full scope Medi-Cal  
            coverage versus Medi-Cal coverage for pregnancy-only services)  
            depends upon her income, immigration status, assets, and  
            whether she meets other criteria (for example, a pregnant  
            woman can only receive full scope coverage if she has  
            "linkage" to Medi-Cal for specified reasons). DHCS indicates a  
            low-income pregnant woman in her first or second trimester  
            with income between 59 and 100 percent of the FPL is eligible  
            for pregnancy only Medi-Cal coverage and does not qualify for  
            full-scope Medi-Cal unless she is otherwise linked to Medi-Cal  
            (such as being on CalWORKS) until she reaches her third  
            trimester. 

          Under federal law, the Medicaid expansion to single adults up to  
            138 percent of the FPL does not include women who are pregnant  
            at the time of application. AB X1 1 and SB X1 1 originally  
            proposed to provide full scope Medi-Cal coverage to pregnant  
            women up to 200 percent of the FPL, but these provisions were  
            removed from the final legislative package so that additional  
            time could be given to instead provide a benefit and  
            affordability wrap for pregnant women with incomes between 100  
            and 200 percent of the FPL who are currently eligible for  
            pregnancy-only Medi-Cal and who may also be eligible for  
            premium and cost-sharing subsidies in Covered California. The  
            benefit and affordability wrap contained in this bill is being  
            removed from this measure as proposed to be amended following  
            stakeholder objection.

          Under this bill, women who are citizens or legal immigrants with  
            family incomes below 100 of the FPL (effectively, women with  
            incomes between 59 percent and 100 percent of the FPL or  
            income between $11,523 and $19,530 for a family of three in  
            2013) would be eligible for full-scope Medi-Cal coverage. This  
            would address an anomaly in the federal Medicaid expansion  
            that provides single adult women and men with broader coverage  
            than would be provided to pregnant women who are currently  
            eligible for pregnancy-only services.




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          3.DHCS use of provider bulletins followed by regulations. The  
            use of provider bulletins in lieu of regulations has been an  
            on-going issue of dispute between the Legislature and DHCS.  
            While the Legislature has authorized the exemption from the  
            rule-making provisions of the Administrative Procedure Act.  
            (APA) when urgent action is needed (such as to immediately  
            implement budget savings proposals) or for ease of program  
            implementation, the requirements set forth in the APA are  
            designed to provide the public with a meaningful opportunity  
            to participate in the adoption of state regulations and to  
            ensure that regulations are clear, necessary and legally  
            valid, and broadly available to the public. In addition, many  
            Medi-Cal policies and program rules are contained in statute,  
            all-county letters and regulations, making it difficult to  
            discern the complex eligibility and related requirements for  
            this program. This bill adopts a compromise in initially  
            allowing the Medi-Cal-related health reform provisions to be  
            adopted by all-county letters or similar instructions but  
            requires the adoption of regulations by July 1, 2015.

          4.Medi-Cal county budgeting methodology changes. County social  
            service departments determine Medi-Cal eligibility on behalf  
            of the state. DHCS is responsible for determining allocation  
            for funding county social service costs associated with  
            Medi-Cal eligibility determinations. AB 102 (Committee on  
            Budget), Chapter 29, Statutes of 2011, required DHCS to  
            develop and implement a new budgeting methodology for Medi-Cal  
            county administrative costs. This bill makes changes to those  
            provisions agreed to by the County Welfare Directors  
            Association and DHCS, including requiring the budgeting  
            methodology to reflect the impact of ACA implementation on  
            county administrative work, and requiring the methodology be  
            implemented no sooner than the 2015-16 fiscal year.

          5.Prior legislation.
             a.   SB 900 (Alquist), Chapter 659, Statutes of 2010,  
               establishes Covered California as an independent public  
               entity within state government, and requires Covered  
               California to be governed by a board composed of the  
               Secretary of California Health and Human Services Agency,  
               or his or her designee, and four other members appointed by  
               the Governor and the Legislature who meet specified  
               criteria.  

             b.   AB 1602 (John A. P�rez), Chapter 655, Statutes of 2010,  




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               specifies the powers and duties of Covered California  
               relative to determining eligibility for enrollment in the  
               Covered California and arranging for coverage under  
               qualified health plans, requires Covered California to  
               provide health plan products in all five of the federal  
               benefit levels (platinum, gold, silver, bronze and  
               catastrophic), requires health plans participating in  
               Covered California to sell at least one product in all five  
               benefit levels in Covered California, requires health plans  
               participating in Covered California to sell their Covered  
               California products outside of Covered California, and  
               requires health plans that do not participate in the  
               Covered California to sell at least one standardized  
               product designated by the Covered California in each of the  
               four levels of coverage, if Covered California elects to  
               standardize products.

             c.   AB 1296 (Bonilla), Chapter 641, Statutes of 2011, the  
               Health Care Eligibility, Enrollment, and Retention Act,  
               requires the California Health and Human Services Agency,  
               in consultation with other state departments and  
               stakeholders, to undertake a planning process to develop  
               plans and procedures regarding these provisions relating to  
               enrollment in state health programs and federal law. AB  
               1296 also established the requirements for the CalHEERS  
               application form.  
            
          6.Proposed author's amendments. The author is proposing to  
            remove Sections 1, 2, 15 and 16 from this bill as amended on  
            August 15, 2013, which would delete provisions establishing a  
            benefit and affordability wrap for pregnant women with incomes  
            between 100 and 200 percent of the FPL. 

          7.Support.  Groups representing health care providers,  
            low-income consumers and women's health advocates, such as the  
            American Congress of Obstetricians and Gynecologists, write in  
            support of the expansion to 100 percent of the FPL but would  
            argue this expansion should also apply to women with incomes  
            up to 138 percent of FPL. In addition, these groups seek  
            amendments to change the pregnancy benefit and cost-sharing  
            wrap provisions that are being removed from this bill. Since  
            these provisions are being removed from the bill, the current  
            position of these groups is unknown.
          .
          8.Opposition. The California Primary Care Association (CPCA)  




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            writes that it is opposed unless amended and seeks changes to  
            the provisions being removed from this bill by the proposed  
            author's amendments, and because the bill does not contain a  
            provision entitling newly qualified immigrants to full-scope  
            Medi-Cal benefits, including Federally Qualified Health  
            Centers (FQHC) services provided at the enhanced FQHC Medi-Cal  
            rate. Because these provisions are being removed from the bill  
            or were not in the bill to begin with, the current position of  
            CPCA is unknown.

          9.Recommended amendments. This bill permits DHCS to implement  
            the expansion of Medi-Cal coverage for pregnant women with  
            incomes below 100 percent of the FPL through the use of  
            provider bulletins but does not specify a date by which  
            regulations must be adopted consistent with the other  
            provisions of this bill. In addition, staff recommends that  
            the Medi-Cal pregnancy related benefits include the phrase  
            "full scope" to clarify the intent of this section. 

           SUPPORT AND OPPOSITION  :
          Positions below are based on the August 15, 2013 version of this  
          bill; the author is removing the benefit and affordability wrap  
          that many groups commented on, sought changes to, and were the  
          principle basis for their amendments and position on the  
          measure.

          Support:       Planned Parenthood Affiliates of California (and  
                    seeks amendments)
                         Western Center on Law & Poverty (and seeks  
                              amendments)

          Support if amended:American Congress of Obstetricians and  
          Gynecologists
                         California Nurse-Midwives Association
                         Maternal and Child Health Access
                         National Health Law Program
                         National Organization for Women California

          Oppose:        California Primary Care Association (unless  
                    amended)



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