BILL ANALYSIS                                                                                                                                                                                                    Ó



                                                                AB 2 X1
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        ASSEMBLY THIRD READING
        AB 2 X1 (Pan)
        As Introduced January 29, 2013
        Majority vote 

         HEALTH              13-6        APPROPRIATIONS      12-5         
         
         ----------------------------------------------------------------- 
        |Ayes:|Pan, Ammiano, Atkins,     |Ayes:|Gatto, Bocanegra,         |
        |     |Bonilla, Bonta, Chesbro,  |     |Bradford,                 |
        |     |Gomez,                    |     |Ian Calderon, Campos,     |
        |     |Roger Hernández,          |     |Eggman, Gomez, Hall,      |
        |     |Lowenthal, Mitchell,      |     |Holden, Pan, Quirk, Weber |
        |     |Nazarian, V. Manuel       |     |                          |
        |     |Pérez, Wieckowski         |     |                          |
        |     |                          |     |                          |
        |-----+--------------------------+-----+--------------------------|
        |Nays:|Logue, Maienschein,       |Nays:|Harkey, Bigelow,          |
        |     |Mansoor, Nestande,        |     |Donnelly, Linder, Wagner  |
        |     |Wagner, Wilk              |     |                          |
        |     |                          |     |                          |
         ----------------------------------------------------------------- 
         SUMMARY  :  Establishes health insurance market reforms contained in  
        the Patient Protection and Affordable Care Act (ACA) specific to  
        individual purchasers, such as prohibiting insurers from denying  
        coverage based on preexisting conditions; and makes conforming  
        changes to small employer health insurance laws resulting from new  
        draft federal regulations.  Specifically,  this bill  : 

         Federal Conformity Issues

         1)Revises existing law as amended by AB 1083 (Monning), Chapter 852,  
          Statutes of 2012, to conform to draft federal rules related to  
          risk pools and prohibits a plan or solicitor from employing  
          marketing practices or benefit designs that will have the effect  
          of discouraging the enrollment of individuals with significant  
          health needs.  

        2)Authorizes a health plan or insurer to vary premium rates for a  
          particular nongrandfathered small employer health benefit plan  
          contract from its index rate based only on the following  
          actuarially justified plan-specific factors:  

           a)   The actuarial value and cost-sharing design of the plan  








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             contract or health benefit plan;

           b)   The plan contract's or health benefit plan's provider  
             network, delivery system characteristics, and utilization  
             management practices; 

           c)   The benefits provided under the plan contract that are in  
             addition to the Essential Health Benefits (EHBs).  Requires  
             these additional benefits to be pooled with similar benefits  
             within the single risk pool and the claims experience from  
             those benefits to be utilized to determine rate variations for  
             plan contracts that offer those benefits in addition to EHBs;  
             and,

           d)   With respect to catastrophic plans, the expected impact of  
             the specific eligibility categories for those plans.

        3)Revises rating factors in existing small group law as follows:   
          includes references to the age rating curve established by the  
          Centers for Medicare and Medicaid Services (CMS), using the  
          individual's age as of the effective date of the contract and  
          specifies the three to one variation limitation is based upon like  
          individuals of different ages who are 21 years of age or older, as  
          described in federal regulations; and, six geographic regions and  
          for 2015 and thereafter, subject to federal approval, 13  
          geographic regions.  Requires the total premium charged to be  
          determined by the sum of the premiums of covered employees and  
          dependents in accordance with federal regulations.  
        
        4)Requires a health plan or insurer to fairly and affirmatively  
          offer, market, and sell all of the plan's health benefit plans  
          that are sold in the individual market for policy years on or  
          after January 1, 2014, to all individuals and dependents in each  
          service area in which the plan provides or arranges for health  
          care services.  Limits enrollment to open enrollment and special  
          enrollment periods, as specified.  

        5)Prohibits in the individual market a health plan or insurer from  
          imposing any preexisting condition provision upon any individual.   

        
        6)Prohibits in the individual market a health plan or insurer from  
          establishing rules for eligibility, including continued  
          eligibility, of any individual to enroll under the terms of an  








                                                                AB 2 X1
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          individual health benefit plan based on any of the following  
          factors:  

           a)   Health status;

           b)   Medical condition, including physical and mental illness;

           c)   Claims experience;

           d)   Receipt of health care;

           e)   Medical history;

           f)   Genetic information;

           g)   Evidence of insurability, including conditions arising out  
             of acts of domestic violence;

           h)   Disability; and,

           i)   Any other health status-related factor as determined by  
             federal regulations, rules, or guidance issued pursuant to  
             federal law.

           7)   Specifies a health plan or insurer is not required to offer  
             an individual health benefit plan or accept applications for  
             the plan under specified circumstances, such as when an  
             individual does not live or reside within the plan's approved  
             service areas.
         
        Federal Conformity Except g) and h) and 63 days

         8)Establishes as an initial open enrollment period from October 1,  
          2013 to March 31, 2014, and annually after that from October 15 to  
          December 7.  This is the period when individuals can purchase  
          health insurance through Covered California, through the  
          California Health Benefit Exchange (Exchange), now called Covered  
          California, and in the commercial market.  In addition, gives  
          individuals 63 days to enroll under one of the following special  
          enrollment trigger events:  

           a)   Loss of minimum essential coverage, as specified under  
             federal requirements;









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           b)   Gaining a dependent or becoming a dependent;

           c)   Mandated coverage due to court order;

           d)   Released from incarceration;

           e)   Health benefit plan substantially violated a material  
             provision of the contract;

           f)   Gained access to a new health benefit plan as a result of a  
             permanent move;

           g)   Provider no longer participating in a plan and individual  
             has a specified condition;

           h)   Misinformed about minimum essential coverage; and,

           i)   For Covered California any events listed under federal  
             regulations.

         Federal Conformity except tobacco rating is excluded

         9)Permits in the individual market only the following  
          characteristics of an individual, and any dependent thereof, for  
          purposes of establishing the rate of the health benefit plan: 
           
           a)   Age, pursuant to age bands established by the Secretary of  
             Health and Human Services (HHS) and the age rating curve  
             established by CMS.  Rates based on age shall be determined  
             using the individual's age as of the date of the plan issuance  
             or renewal, as applicable, and shall not vary by more than  
             three to one for like individuals of different age who are age  
             21 or older as described in federal regulations.

           b)   Geographic regions based on six regions for 2014, and 13  
             regions for 2015 and each plan year thereafter, subject to  
             federal approval if required, and obtained by the Department of  
             Managed Health Care (DMHC) and the California Department of  
             Insurance (CDI).  Requires no later than June 1, 2017, DMHC and  
             CDI in collaboration with the Exchange, to review the  
             geographic rating regions and the impacts of those regions on  
             the health care coverage market in California and make a report  
             to the appropriate policy committees of the Legislature.









                                                                AB 2 X1
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           c)   Whether the plan covers an individual or family, as  
             described in the ACA.  (The rating variation permitted shall be  
             applied to each family member.  However the total premium shall  
             be determined by the sum of the premiums for each family member  
             but for no more than the three oldest members under age 21.)
         
        California Specific Issues

         10)Requires any data submitted by a health plan or health insurer to  
          the Secretary of HHS, or her designee, for purposes of the risk  
          adjustment program described in the ACA, to also be concurrently  
          submitted to the DMHC or CDI.
        
        11)Requires health plans and insurers to provide a notice to all  
          applicants for coverage related to guarantee issue for children  
          about other options for enrollment including new open enrollment  
          options.  Authorizes DMHC to develop a model notice requirement,  
          in consultation with CDI.  Authorizes CDI to develop a model  
          notice requirement, in consultation with DMHC.  Exempts this model  
          notice authority from the Administrative Procedures Act.  Sunsets  
          this article on January 1, 2014.

        12)Establishes definitions for individual market provisions, similar  
          to the definitions established for the small group in existing  
          law.  Defines health benefit plan as any individual or group  
          health plan or policy of health insurance as defined, and  
          specifies what it does not include, such as Medi-Cal.  Defines a  
          dependent as the spouse or registered domestic partner or child of  
          an individual, subject to applicable terms of the health benefit  
          plan. 

        13)Requires a health plan or insurer outside the Exchange to inform  
          an applicant for coverage that he or she may be eligible for lower  
          cost coverage through the Exchange and the Exchange enrollment  
          period.  (Does not apply to grandfathered plans.)

        14)Requires a health plan or insurer outside the Exchange to issue a  
          notice to a subscriber that he or she may be eligible for lower  
          cost coverage through the Exchange and shall inform the subscriber  
          of the applicable open enrollment period provided through the  
          Exchange.  (Does not apply to grandfathered plans.)

        15)Requires a grandfathered health benefit plan to issue the  
          following notice annually and in any renewal material:








                                                                AB 2 X1
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             New improved health insurance options are available in  
             California.  You currently have health insurance that  
             is exempt from many of the new requirements.  For  
             instance, your plan may not include certain consumer  
             protections that apply to other plans, such as the  
             requirement for the provision of preventive health  
             services without any cost sharing and the prohibition  
             against increasing your rates based on your health  
             status.  You have the option to remain in your current  
             plan or switch to a new plan.  Under the new rules, a  
             health plan cannot deny your application based on any  
             health conditions you may have.  For more information  
             about your options, please contact the California  
             Health Benefit Exchange, the Office of Patient  
             Advocate, your plan representative, an insurance  
             broker, or a health care navigator. 

        16)Requires a plan participating in the Healthy Families program to  
          notify a qualified beneficiary within 30 days of the operative  
          date of opportunities to purchase or maintain coverage.  Permits a  
          qualified beneficiary to elect coverage within 60 days of the  
          mailing of the notice.

        17)Requires a qualified beneficiary receiving coverage pursuant to  
          this part to make premium payments of not more than 110% of the  
          average per subscriber payment made by the board or department to  
          all participating plans for coverage provided.

        18)Prohibits a health plan or health insurer from advertising or  
          marketing an individual health benefit plan that is grandfathered  
          for the purpose of enrolling a dependent for policy years on or  
          after January 1, 2014.  Nothing prevents a grandfathered plan from  
          adding a dependent.




         EXISTING LAW  :

        1)Establishes DMHC to regulate health plans under the Knox-Keene  
          Health Care Services Plan Act of 1975 in the Health and Safety  
          Code; CDI to regulate health insurers under the Insurance Code;  
          and, the Exchange to compare and make available through selective  








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          contracting health insurance for individual and small business  
          purchasers as authorized under the ACA.
          
        2)Defines a grandfathered health plan as having the same meaning as  
          that term is defined in the ACA.  Federal law defines  
          grandfathered health plan as any group health plan or health  
          insurance coverage to which Section 1251 of the ACA applies (in  
          general coverage that existed as of March 23, 2010, which can only  
          enroll new individuals as dependents of existing covered  
          individuals).

        3)Prohibits a nongrandfathered health benefit plan for group or  
          individual coverage from imposing any preexisting condition  
          provision or waivered condition upon any enrollee, and requires on  
          or after October 1, 2013, a plan to fairly and affirmatively  
          offer, market, and sell all small employer health plan contracts  
          for plan years on or after January 1, 2014, to all small employers  
          in each service area, as specified (pursuant to AB 1083).

        4)Establishes that premium rates for small employer health benefit  
          plan contracts can vary only by age, pursuant to age bands,  
          established by the Secretary of HHS, and based on the individual's  
          birthday and shall vary by no more than three to one for adults;  
          includes 19 geographic regions, as specified, with a report no  
          later than June 1, 2017, reviewing the impact of the regions on  
          the coverage market in California; and, whether the contract  
          covers an individual or family, as described in the ACA (pursuant  
          to AB 1083).
        
        5)Requires health plans and insurers with contracts and policies in  
          the individual market to allow without medical underwriting an  
          individual to transfer once a year to a contract that has equal or  
          lesser benefits.
        
        6)Requires health plans and health insurers with contracts and  
          policies in the individual market to offer an individual in a  
          contract or policy that was rescinded without medical underwriting  
          a new individual contract or policy with equal benefits.  
        
        7)Establishes notification and rate requirements for individuals  
          eligible for coverage under the Health Insurance Portability and  
          Accountability Act of 1996.  

        8)Establishes conditions for guaranteed issue of coverage for  








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          children.  

         FISCAL EFFECT  :  According to the Assembly Appropriations Committee,  
        this bill would have special fund costs to the CDI Insurance Fund  
        and Managed Health Care (DMHC Managed Care Fund) to adopt/modify  
        regulations, review plan and insurer filings and respond to  
        consumers.  For CDI, costs are estimated at about $600,000 for  
        fiscal year 2013-14 and $283,000 for 2014-15.  DMHC's costs will  
        likely be in a similar but lower range because DMHC plans will not  
        be changing their business practices to the same extent that will be  
        required by CDI insurers. 

         COMMENTS  :  This bill contains clean-up provisions to AB 1083 which  
        enacted insurance market reforms consistent with the ACA affecting  
        health insurance sold to small employer purchasers and establishes  
        insurance market reforms consistent with the ACA affecting the  
        health insurance market for individual purchasers.  An important  
        general objective of the ACA state implementing legislation is to  
        ensure that the rules in the Exchange and outside the Exchange, as  
        well as in both the small group and individual markets, are as  
        similar as possible in an effort to avoid adverse selection.

        Clean-up provisions are necessary because new draft federal  
        regulations have been issued which require updating of the AB 1083  
        provisions.  In addition, while the Legislature approved AB 1461  
        (Monning) and SB 961 (Ed Hernandez) in 2012, which would have  
        established insurance market rules for individual purchasers, both  
        bills were vetoed by the Governor because a provision to link or  
        "tie back" state law to federal law was viewed as insufficient.  As  
        a result, Covered California has initiated a Qualified Health Plan  
        (QHP) solicitation process based on assumptions of what might be the  
        individual market rules in California.  Health insurers bidding to  
        be QHPs must submit premium bids to Covered California by March 31,  
        2013, in order to ensure they receive regulatory review in time for  
        Covered California to begin marketing and offering those plans in  
        October of 2013.  The rules established and revised by this bill  
        would apply to health insurance sold through Covered California as  
        well as insurance products sold in the commercial market outside of  
        Covered California, and need to be in place as soon as possible in  
        time for the regulatory reviews required for QHPs.  It is necessary  
        to put the federal rules in state law for state regulatory  
        enforcement purposes.  

        On January 24, 2013, Governor Brown issued a proclamation to convene  








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        the Legislature in Extraordinary Session to consider and act upon  
        legislation necessary to implement the ACA in the areas of:  1)  
        California's private health insurance market, rules and regulations  
        governing the individual and small group market; 2) California's  
        Medi-Cal program and changes necessary to implement federal law;  
        and, 3) options that allow low-cost health coverage through Covered  
        California to be provided to individuals who have income up to 200%  
        of the federal poverty level.  This bill along with SB 2 X1 (Ed  
        Hernandez) address the first of the three areas identified in the  
        Governor's proclamation. 

        On March 23, 2010, the federal ACA (Public Law 111-148), as amended  
        by the Health Care and Education Reconciliation Act of 2010 (Public  
        Law 111-152) became law.  Among many other provisions, the new law  
        makes statutory changes affecting the regulation of and payment for  
        certain types of private health insurance.  Beginning in 2014,  
        individuals will be required to maintain health insurance or pay a  
        penalty, with exceptions for financial hardship (if health insurance  
        premiums exceed 8% of household adjusted gross income), religion,  
        incarceration, and immigration status.  Several insurance market  
        reforms are required, such as prohibitions against health insurers  
        imposing preexisting health condition exclusions.  These reforms  
        impose new requirements on states related to the allocation of  
        insurance risk, prohibit insurers from basing eligibility for  
        coverage on health status-related factors, allow the offering of  
        premium discounts or rewards based on enrollee participation in  
        wellness programs, impose nondiscrimination requirements, require  
        insurers to offer coverage on a guaranteed issue and renewal basis,  
        and determine premiums based on adjusted community rating (age,  
        family, geography and tobacco use).  Final rules were issued on the  
        ACA health insurance market rules on Friday, February 22, 2013.

        According to a February 6, 2013, Kaiser Family Foundation (KFF)  
        article, "Why Premiums Will Change for People Who Now Have Nongroup  
        Insurance," overall, it is expected that average, unsubsidized  
        premiums in the nongroup (individual) market will be somewhat higher  
        under the ACA as compared to today.  This is because many people  
        will be getting better insurance with EHBs like maternity care and  
        mental health.  (Note: California already mandates maternity and  
        mental health parity for severe mental illness).  Also patient cost  
        sharing for out-of-pocket costs will be capped.  Guaranteed access  
        to coverage for people with preexisting conditions may increase  
        average premiums as many people with higher costs come into the  
        system.  However, this should be balanced by more, healthy, young  








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        uninsured people participating because of subsidies and the  
        individual mandate.  Restricting access to coverage during annual  
        and special enrollment periods will reduce the likelihood that  
        people will wait until they develop health problems before seeking  
        coverage.

        The ACA provides for $20 billion in transitional reinsurance to  
        offset adverse selection in the first three years of the program.   
        The ACA also redistributes the premium burden among different  
        enrollees by eliminating premium differences for gender and limiting  
        variation in premiums due to age to a maximum of three to one.  This  
        has led to concerns about "rate shock" but premium increases for  
        young people are mitigated by premium subsidies and that people  
        under 30 can purchase catastrophic coverage.  The KFF article  
        details how each of the insurance market changes in the ACA may  
        raise or lower premiums overall or redistribute them among different  
        groups of people.  In the big picture, the ACA addresses many of the  
        shortcomings of the current individual market.  The more competitive  
        marketplace created under the ACA, greatly enhanced by the structure  
        of premium tax credits, will push in the other direction forcing  
        health plans to become more efficient and better managers of the  
        premiums they receive.  There is already some evidence that plans  
        are working to create less costly, more efficient networks to offer  
        with plans sold in exchanges.

        Provisions of the ACA are intended to address affordability of  
        health care coverage.  Subsidies for purchasing health insurance  
        will be available in the Exchange for some individuals whose  
        coverage costs exceed a certain percentage of their income, and  
        other individuals will be exempt from the individual mandate if  
        costs exceed a specified percentage of their income (8%).   
        Surcharges associated with tobacco use and standards-based wellness  
        incentive programs could make coverage unaffordable for some  
        populations and take them out of the health insurance market  
        altogether.  While the ACA allows for tobacco rating, this bill does  
        not include tobacco rating as a factor for determining premium  
        rates.

        The ACA requires that each state establish geographic rating areas  
        that must be applied consistently inside and outside the Exchange.   
        The final federal rules allow states to establish rating areas by  
        selecting from the following options:  1) one or more rating areas  
        for the state; 2) based on county, three-digit zip code, or  
        metropolitan statistical areas (MSAs) and non-MSA geographic  








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        divisions; and, 3) are presumed adequate if the state established by  
        law, rule, regulation, bulleting or other executive action uniform  
        rating areas for the entire state as of January 1, 2013, or, the  
        state establishes them in the same manner after January 1, 2013,  
        that are no greater in number than the number of MSAs in the state  
        plus one (there are 26 MSAs in CA).

        AB 1083 included a 19 rating region proposal, different than the  
        region proposal in this bill and SB 2 X1.  The 19 represent an  
        expanded version of an earlier proposal developed by the California  
        Association of Health Plans (CAHP) that split up Bay Area counties  
        into their own regions because of an incorrect interpretation  
        related to how the subsidies would be determined.  To be consistent  
        with the draft rules, this bill establishes, for both the small  
        group market and the individual market, the geographic rating  
        regions for the first year to be the existing Pre-Existing Condition  
        Insurance Plan six rating regions.  This bill then establishes 13  
        rating regions developed by CAHP for future years if federal  
        approval is granted, again consistent with the proposed rules.   
        Covered California has requested QHP bids due in March 2013 assuming  
        that the 19 rating regions included in AB 1083 enacted prior to the  
        issuance of draft federal regulations would be adopted by the  
        Legislature and approved by the Governor for the individual market  
        as well.

        As previously indicated, Governor Brown vetoed AB 1461 and SB 961  
        because the tie back provision was not sufficient to meet the  
        Governor's concerns.  AB 1461 and SB 961 contained a tie back for  
        the state guarantee issue provision and the state community rating  
        provision, meaning that if the federal guarantee issue and community  
        rating requirements were to be repealed, the state guarantee issue  
        and community rating provisions would automatically become  
        inoperative at the state level.  The Brown Administration has  
        requested a broader tie-back to the ACA that would also make  
        inoperative state provisions prohibiting preexisting condition  
        exclusions and prohibiting eligibility rules based on health status  
        factors.

        This bill creates a new requirement on health, dental, and vision  
        plans covering the Healthy Families program (HFP) population to  
        offer to children aging out of HFP at age 19 the same coverage at a  
        premium rate of not more than 110% of the rate paid by the Managed  
        Risk Medical Insurance Board.  This requirement applies to  
        individuals aging out of HFP on or after January 1, 2012, and is in  








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        place until January 1, 2014, or six months after the operative date  
        of this bill.  This is a new provision intended to serve as a  
        coverage bridge, particularly for 19 year olds with preexisting  
        conditions until the ACA reforms are fully implemented in 2014.

        Supporters agree that this bill provides vital protection to  
        California consumers of health care coverage.  They write in support  
        of the guaranteed issue of coverage provisions that prohibit  
        insurers from denying coverage based on pre-existing conditions and  
        other health status-related factors.  The California Public Interest  
        Research Group (CALPIRG) writes that in 2009 nearly 6.5 million  
        Californians had pre-existing conditions that would have prevented  
        them from attaining coverage in the individual market and that  
        nationally 47% of individuals applying for insurance were either  
        denied or offered insurance at a much higher rate.  The Transgender  
        Law Center argues that this bill will optimize coverage for all  
        Californians and is fully inclusive of registered domestic partners  
        to the same extent as spouses.  Health Access California (HAC) and  
        CALPIRG point out that this bill limits insurers to only raising  
        rates one time per year which improves price stability and helps  
        individuals and families to budget for their health coverage.   
        Consumers Union (CU) and HAC support the limitation of the  
        geographic regions, explaining that allowing more rating regions  
        provides a greater opportunity in the rate making process for  
        inappropriate targeting of certain subscribers forcing higher rates  
        on those targeted populations.  HAC and CU agree that while the ACA  
        does allow for tobacco rating, this bill does not; that tobacco  
        rating has not been proven to reduce smoking and can lead to pricing  
        smokers, who need health insurance, right out of the market.

        The 100% Campaign, Children's Partnership, Children Now, and  
        Children's Defense Fund, California all write that they support this  
        bill in concept.  They state the ACA implements considerable reforms  
        including banning discriminatory practices by insurance companies of  
        denying coverage to individuals with pre-existing conditions and  
        charging higher rates to individuals based on health status.   
        Currently, insurers are not allowed in California to deny coverage  
        to children based on a pre-existing condition, but are still allowed  
        to charge a sick child twice the premium of a healthy child and this  
        bill eliminates that practice.  Additionally, these groups believe  
        that the notices to consumers as required in this bill will assist  
        families in making better informed decisions on their health care  
        coverage.









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        CDI is opposed to this bill unless it is amended.  CDI writes that  
        the selection of geographic rating regions is one the most  
        significant choices the state has the authority to make that will  
        impact the affordability of health insurance for consumers.   
        Currently insurance companies and health plans set their own  
        geographic rating areas.  CDI's actuarial staff conducted extensive  
        analysis of the different rating region structures that have been  
        proposed.  According to CDI's data the proposed six and 13  
        geographic regions would result in an estimated maximum premium  
        increases of 23% and 25% respectively; the 19 proposed in AB 1461  
        would also result in an estimated 25% maximum premium increase.  CDI  
        proposes an 18 region plan that they argue would best minimize  
        premium disruption in the marketplace by reducing it to a maximum of  
        8%.

        The California Association of Health Plans and the Association of  
        California Life and Health Insurance Companies also oppose this bill  
        unless it is amended.  They both argue the guaranteed issue and  
        community rating reforms in this bill should be linked to the same  
        reforms in the ACA and that it would be a mistake for California to  
        "go it alone" without the federal protections of the ACA.  They are  
        concerned that this bill is placing proposed federal rules into  
        statute and that more flexibility is needed in case these rules are  
        modified.  Both associations claim that while the current 19  
        geographic rating regions are not perfect, keeping them would  
        balance the need to avoid rate disruption to existing enrollees with  
        creating regions that reflect the cost of care in local regional  
        health care markets while maximizing subsidies.


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


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