BILL ANALYSIS                                                                                                                                                                                                    �




                                                                  AJR 17
                                                                  Page A
          Date of Hearing:  June 10, 2013

                     ASSEMBLY COMMITTEE ON REVENUE AND TAXATION
                                Raul Bocanegra, Chair

                  AJR 17 (Patterson) - As Introduced:  April 8, 2013

          Majority vote.

           SUBJECT  :  Federal tax: medical devices: repeal
           
          SUMMARY  :  Urges the President and Congress of the United States  
          (U.S.) to repeal the excise tax on medical devices to protect  
          the medical device industry and its consumers.   

          EXISTING FEDERAL LAW:

           1)Imposes an excise tax on the sale of certain medical devises.   
            [Internal Revenue Code (IRC) Section 4191].  

          2)Specifies that the excise tax is 2.3% of the price for which  
            the taxable medical device is sold. 

           EXISTING STATE LAW  does not conform to IRC Section 4191 and does  
          not impose an excise tax on sales of medical devices. 
           
          FISCAL EFFECT  :  Unknown
           
          COMMENTS:   

          1)The Author's Statement  .  The author states that, "The federal  
            excise tax on medical devices will have crippling effects on  
            the medical device industry and its consumers and the effort  
            to repeal the tax has received bipartisan support in Congress  
            - including support from any legislators who support the  
            Affordable Care Act itself.

          "California is home to over 1,200 medical device companies that  
            employ over 100,007 Californians.  Since California makes up  
            over 20% of the nation's medical device industry, the tax  
            disproportionately affects our state.  Companies throughout  
            the state and nation have already announced anticipated  
            layoffs and setbacks in research and development efforts as a  
            result of the lost revenue from this tax.










                                                                  AJR 17
                                                                  Page B
          "In addition to the imminent loss of jobs in California, the  
            excise tax on medical devices will result in increased costs  
            for our state's most vulnerable population - the sick and the  
            elderly.

          "It is essential that we urge Congress to repeal this tax so  
            that our state can continue to be the leader in the research  
            and development of medical technology and so that California's  
            economy and citizens do not suffer."  

          2)An Excise Tax on Medical Devices.   The Affordable Care Act  
            (ACA) imposes a 2.3% excise tax on the sale of any taxable  
            medical device by the manufacturer or importer of the device.   
            The tax applies to sales that take place after December 31,  
            2012.  Certain medical devices are exempt from this excise  
            tax:  eyeglasses, contact lenses, and hearing aids.  There is  
            also an exemption for any other medical device that is  
            purchased by the general public at retail for individual use.   
            Furthermore, a manufacturer or importer of a taxable medical  
            device may, in certain circumstances, sell a taxable medical  
            device tax-free for use by the purchaser for further  
            manufacture (or for resale by the purchaser to a second  
            purchaser for further manufacture), or for export (or for  
            resale for export).  But, in order to make such a tax-free  
            sale, both parties to the sale must be registered with the  
            Internal Revenue Service.   

          3)Should the Excise Tax Be Repealed  ?  While some argue that the  
            medical device tax, like any other excise tax, is harmful and  
            creates distortions in the medical device industry,<1> other  
            researchers believe that "the arguments against the tax don't  
            withstand scrutiny."<2>  

          Thus, the Tax Foundation report states that the medical device  
            excise tax will increase the cost of the products on which it  
            is levied and will adversely affect innovation, employment,  
            and competition "in the same way the windfall profits tax of  
            the 1980s depressed domestic oil production."  While  
            manufacturers will try to pass the tax onto consumers in the  
            form of higher prices, the "market power of hospitals could  
          ---------------------------
          <1> Tax Foundation, The ACA Medical Device Tax: Bad Policy in  
          Need of Repeal, April 9, 2013, No. 364.
          <2> Center on Budget and Policy Priorities, Excise Tax on  
          Medical Devices Should Not Be Repealed (Industry Lobbyists  
          Distort Tax's Impact),  March 11, 2013. 








                                                                  AJR 17
                                                                  Page C
            undercut the ability of device manufacturers to pass on much  
            of the cost of this tax in the long run."  (Tax Foundation  
            report, p. 3).  Furthermore, it is argued that the medical  
            device tax comes with compliance costs, which will place an  
            additional, disproportionate administrative burden on smaller  
            firms.  Finally, the report concludes that this tax will  
            result in higher health care costs, which undermines the  
            objective of the ACA, targets one industry, and makes it  
            overall bad tax policy.  

          The Center on Budget and Policy Priorities (CBBP), however,  
            believes that, from the tax policy perspective, the medical  
            device tax is sound.  It does not single out the medical  
            device industry for unfair treatment, will not cause  
            manufacturers to shift production overseas, and will have  
            little effect on innovation in the medical device industry.   
            In fact, the CBBP report states that the "health reform may,  
            on balance, benefit the medical device industry and boost its  
            sales."  The report reasons that the ACA, by extending health  
            coverage to 27 million more Americans, or by nearly 10%, will  
            increase the demand for medical devices and, consequently, the  
            revenue of device manufacturers.   

          4)The Congressional Action  .  On March 21, 2013, the U.S. Senate  
            voted 79 to 20 to pass a non-binding budget amendment to the  
            Fiscal Year 2014 Budget Resolution encouraging the repeal of  
            the ACA's medical device excise tax (the "Hatch-Klobuchar  
            Amendment").  Last year, the House passed H.R. 436, which  
            would have repealed the tax, and similar bills have been  
            introduced in Congress this year as well.  

          It should be noted that the Hatch-Klobuchar amendment required  
            that the revenue loss be completely offset with new  
            undetermined revenues. The Joint Committee on Taxation  
            estimates that repealing this excise tax would cost $29  
            billion over the 2013-2022 period. (Description of H.R. 436,  
            The "Protect Medical Innovation Act of 2011," Publication  
            JXC-45-12, May 29, 2012).  Thus, if the medical device tax  
            were actually repealed, Congress would have been required to  
            increase other taxes or reducing spending.  However, the vote  
            on the Hatch-Klobuchar amendment was non-binding and has no  













                                                                  AJR 17
                                                                  Page D
            effect on existing law.<3>  In other words, Congress declined  
            to change the existing law and, instead, opted to vote on a  
            non-binding amendment.  Given that the Congress has stopped  
            short of repealing the medical device tax, this Committee may  
            wish to consider whether AJR 17, which urges the repeal  
            without offering an alternative funding source to replace the  
            lost revenues, is an appropriate response to the congressional  
            actions.  This resolution simply points out an issue with  
            which the Congress is keenly aware, but makes no mention of  
            how the revenue loss from the repeal would be offset.  

           REGISTERED SUPPORT / OPPOSITION  :   

           Support 
           
          California Healthcare Institute

           Opposition 
           
          None on file
           
          Analysis Prepared by  :  Oksana Jaffe / REV. & TAX. / (916)  
          319-2098 














          ---------------------------
          <3> In the words of Dean Zerbe, "the vote [on the  
          Hatch-Klobuchar Amendment] was in essence - "yes I'd like to  
          replace this stupid tax by raising some unknown tax on unknown  
          persons at an unknown time."  (Dean Zerbe, Medical Device tax:  
          Stop Dreaming and Start Planning, Forbes, April 9, 2013).