BILL ANALYSIS                                                                                                                                                                                                    �



                                                                  AB 617
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          Date of Hearing:  April 23, 2013

                            ASSEMBLY COMMITTEE ON HEALTH
                                 Richard Pan, Chair
                   AB 617 (Nazarian) - As Amended:  April 15, 2013
           
          SUBJECT  :  California Health Benefit Exchange: appeals.

           SUMMARY  :  Establishes an applicant's or enrollee's right to  
          appeal actions, inaction, or decisions made by the California  
          Health Benefit Exchange (known as Covered California) that  
          relate to enrollment, eligibility, or ineligibility for a state  
          health subsidy program, for advance payment of the premium tax  
          credits (APTC), and cost-sharing reductions, the amount of the  
          APTC or cost-sharing or eligibility for affordable plan options.  
           Includes right to appeal the determination of an exemption from  
          penalties for failing to meet minimum standards for obtaining  
          health care coverage and failure to provide timely notices as  
          specified.  Specifically,  this bill  :  

          1)Requires Covered California to contract with the Department of  
            Social Services (DSS) to serve as the appeals entity to hear  
            appeals of enrollment, eligibility determinations, or  
            redeterminations for persons obtaining coverage in the  
            individual market.  Requires, unless otherwise provided,  
            Medi-Cal hearing process rules to govern.  

          2)Requires the entity making enrollment or eligibility  
            determinations, including the amounts of APTC and cost-sharing  
            determinations to provide notice of the appeals process at the  
            time of enrollment, application, and determination of  
            eligibility.

          3)Requires the entity making the enrollment or eligibility  
            determinations, to issue a combined eligibility notice, as  
            specified in federal regulations, that includes the following:

             a)   Information about each state health subsidy program that  
               the individual or other members of the household have been  
               determined to be eligible or ineligible for and the  
               effective date of eligibility and enrollment;

             b)   Information about eligibility for modified adjusted  
               gross income (MAGI)-exempt Medi-Cal and the benefits and  
               the services which are available, sufficient to enable the  








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               individual to make an informed decision as to whether to  
               appeal the enrollment or eligibility determination;

             c)   Instructions describing the right to, and process for,  
               appeal of an action relating to eligibility or enrollment  
               for any state health subsidy program, as defined by  
               reference to the federal Affordable Care Act (ACA), under  
               existing procedures applicable to the right to a fair  
               hearing to appeal actions regarding public benefits;

             d)   The right to self-representation or representation by  
               legal counsel or an authorized representative; and, 

             e)   Information regarding the circumstances under which  
               eligibility shall be retained or reinstated pending an  
               appeal decision.

          4)Requires DSS to allow an applicant or enrollee to request an  
            appeal within 90 days of the notice of an eligibility  
            determination, unless there is good cause as defined in  
            existing law relating to a fair hearing to appeal actions  
            regarding public benefits.

          5)Requires the appeal entity to establish an expedited appeal  
            process where there is immediate need for health services  
            because a standard appeal would jeopardize the appellant's  
            life, health, or the ability to attain, maintain, or regain  
            maximum function.  Requires, if an expedited appeal is  
            granted, the decision to be issued within three working days  
            or as soon as is required by the appellant's condition.   
            Requires, if an expedited appeal is denied, the appeals entity  
            shall notify the appellant within two days by telephone or  
            commonly available electronic means, to be followed in  
            writing, of the denial of an expedited appeal.  Requires, if  
            an expedited appeal is denied, the appeal to be handled  
            through the standard appeal process.

          6)Allows an appeal request to be submitted by telephone, by  
            mail, through the Internet, by commonly available electronic  
            means, or by facsimile.

          7)Requires the staff of the Exchange, the county, and the  
            Managed Risk Medical Insurance Board (MRMIB) to assist the  
            applicant or enrollee in making the appeal request.









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          8)Requires, upon receipt of an appeal request, the appeals  
            entity to send acknowledgement in a timely manner and to  
            include:

             a)   Information relating to the appellant's eligibility for  
               benefits while the appeal is pending;

             b)   An explanation that advance payments of the premium tax  
               credit while the appeal is pending are subject to  
               reconciliation; and,

             c)   An explanation that the appellant may participate in  
               informal resolution process, as specified.

          9)Requires DSS, upon receipt of an appeals request, to notify  
            the Exchange and the county and, if related to the Access for  
            Infants and Mothers Program (AIM) to MRMIB via secure  
            electronic interface and requires the entity that made the  
            eligibility or enrollment determination to transmit the  
            eligibility record for use in the adjudication, as specified.

          10)Prohibits a member or employee of the Exchange, a county,  
            MRMIB, or the appeals entity from limiting or interfering with  
            the applicants or enrollee's right to make an appeal.

          11)Allows an applicant or enrollee to be represented by counsel  
            or designate an authorized representative to act on his or her  
            behalf.

          12)Provides for the opportunity for an informal resolution prior  
            to the hearing by providing an opportunity for a  
            representative of the Exchange, the county, or MRMIB to  
            contact the individual and offer to discuss the case if she or  
            he agrees, and preserves the right to a hearing if appellant  
            is dissatisfied with the outcome of the informal resolution  
            process, unless the appellant or authorized representative  
            withdraws the request for hearing, or conditionally  withdraws  
            with specified agreed upon conditions.  

          13)Prohibits the informal resolution process from being  
            mandatory, delaying the timeline for provision of a hearing,  
            and having an effect on the right to a hearing.

          14)Requires, for enrollment or eligibility determinations for  
            state health subsidy programs based on MAGI, the appellant  








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            to initiate the informal resolution process with the entity  
            that made the enrollment or eligibility determination, with  
            the exception of the following:

             a)   Requires the Exchange to conduct informal resolution  
               involving issues related only to the Exchange, including,  
               but not limited to, exemption from the individual  
               responsibility penalty, offers of affordable employer  
               coverage, special enrollment periods, and eligibility for  
               affordable plan options;

             b)   Requires counties to conduct informal resolution  
               involving issues related to non-MAGI Medi-Cal.

             c)   Requires MRMIB to conduct informal resolution  
               involving issues related only to the AIM Program or the  
               Healthy Families Program.

          15)Provides that if the appeal advances to a hearing, the  
            appellant shall not be required to provide duplicative  
            information or documentation that he or she previously  
            provided during the application, redetermination, or informal  
            resolution processes.

          16)Requires the staff involved in the informal resolution  
            process to try to resolve the issue through a review of case  
            documents, and provide the appellant the opportunity to review  
            case documents, in person or through electronic means, verify  
            the accuracy of submitted documents, and submit updated  
            information or provide further explanation of previously  
            submitted documents.

          17)Requires, by reference, the informal process established by  
            DSS to be used for the informal process established pursuant  
            to this bill.

          18)Requires a position statement, if required of a public or  
            private agency by regulation or if the public or private  
            agency chooses, concerning the issues in question, to be  
            electronically available at least two working days before the  
            hearing on the appeal. 

          19)Requires notice of the hearing, with date, time and location,  
            as specified, to the appellant no later than 15 days prior to  
            the hearing date.  Requires reasonable efforts to allow  








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            participation of the appellant and requires notice that the  
            appellant may request the hearing to be held via telephone or  
            video conference and instructions for submitting the request  
            by telephone or other commonly available electronic means. 

          20)Requires the format of the hearing to be in person unless the  
            appellant requests the hearing be held telephonically or via  
            video teleconference. 

          21)Requires the hearing to be conducted by one or more impartial  
            officials who have not been directly involved in the  
            eligibility or enrollment determination or any prior appeal  
            decision in the same matter.

          22)Requires the appellant to be allowed the opportunity to  
            review his or her appeal record, case file, and all documents  
            to be used by the appeals entity at the hearing, at a  
            reasonable time before the date of the hearing, as well as  
            during the hearing.

          23)Requires the hearing to be an evidentiary hearing where the  
            appellant may present evidence, bring witnesses, establish all  
            relevant facts and circumstances, and question or refute any  
            testimony or evidence, including the right to confront and  
            cross-examine adverse witnesses, if any. 

          24)Requires cases and evidence to be reviewed de novo by the  
            appeals entity.

          25)Requires decisions to be made within 90 days from the date  
            the appeal is filed, and based exclusively on the application  
            of the applicable laws, enrollment and eligibility rules to  
            the information used to make decision, as well as, any other  
            information provided by the appellant during the course of the  
            appeal.  

          26)Requires the content of the decision of appeal to include a  
            decision with a plain language description of the effect of  
            the decision on the appellant's eligibility or enrollment, a  
            summary of the facts relevant to the appeal, an identification  
            of the legal basis for the decision, and the effective date of  
            the decision, which may be retroactive.

          27)Requires, upon adjudication of the appeal, the appeals entity  
            to transmit the decision of appeal to the entity that made the  








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            determination of eligibility or enrollment via a secure  
            electronic interface.

          28)Provides that an appellant may make an appeal request  
            regarding issues relating to the Exchange to the federal  
            Department of Health and Human Services (DHHS) within 30  
            days of the notice of the decision and provides that an  
            appellant may also seek judicial review to the extent  
            provided by law regardless of an appeal to DHHS.

          29)Prohibits the contents of this bill from being construed  
            to limit or reduce an appellant's rights to notice,  
            hearing, and appeal under Medi-Cal, county indigent  
            programs, or any other public programs.

           EXISTING LAW  :  

          1)Establishes, under state and federal law, the Medicaid program  
            as a joint federal and state program offering a variety of  
            health and long-term services to low-income women and  
            children, low-income residents of long-term care facilities,  
            seniors, and people with disabilities. 

          2)Provides for Medi-Cal eligibility to be determined at a county  
            social service agency by an eligibility worker or  
            automatically in the case of a person who qualifies for other  
            programs such as CalWorks or is a low-income senior or person  
            with disabilities.

          3)Under the federal ACA, effective January 1, 2014, requires an  
            individual to have the option to apply for state subsidy  
            programs, which includes the state Medicaid program, the state  
            Children's Health Insurance Program (CHIP), enrollment in a  
            qualified health plan (QHP) through a state exchange and a  
            Basic Health Plan (BHP), if there is one, by either in person,  
            mail, online, telephone, or other commonly available  
            electronic means. 

          4)Under the ACA, effective January 1, 2014, requires development  
            of a single, accessible standardized application for the state  
            subsidy programs to be used by all eligibility entities and  
            establishes a process for developing and testing the  
            application.  

          5)Under the ACA, effective in 2014, requires individuals to  








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            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 and creates the Exchange, as an  
            independent state entity governed by a five-member board, to  
            be a marketplace for Californians to purchase affordable,  
            quality health care coverage, claim APTC and cost-sharing  
            subsidies, and as a way to meet the personal responsibility  
            requirements of the ACA.  

          6)Under the ACA, effective January 1, 2014 requires states to  
            extend Medi-Cal coverage to former foster youth up to age 26,  
            eliminate the asset test for certain groups of applicants to  
            Medi-Cal and establish a new methodology for counting income  
            in Medi-Cal, known as MAGI.

          7)Under the ACA, effective January 1, 2014, provides 100%  
            federal matching funds to states to expand Medicaid coverage  
            of adults under age 65 who are not currently eligible with  
            incomes up to 138% of the federal poverty level (FPL),  
            decreasing to 95% in 2017; 94% in 2018; 93% in 2019; and 90%  
            thereafter.

          8)Under state and federal law, provides that Medicaid coverage  
            and benefits are a vested, property right entitled to the  
            protections of due process of law, including the right to a  
            fair hearing when adverse action is taken. 

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

           COMMENTS  :

           1)PURPOSE OF THIS BILL  .  According to the author this bill  
            establishes a "no wrong door" appeals procedure for both  
            Exchange and MAGI eligibility and enrollment determinations.   
            It is also intended to establish an equitable notice procedure  
            by requiring the entity that made the determination, either  
            the Exchange or the counties, to provide to the applicant, a  
            notice on appeal options available.  The author states that  
            this bill ensures the overall purpose of the ACA is achieved;  
            that people are enrolled and receiving benefits from  
            healthcare coverage programs they can afford.  The author  
            argues, consistent with the goal of the ACA, this bill  
            implements a coordinated, statewide approach on appeals to  








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            facilitate the process and to seamlessly enroll consumers in  
            health coverage.  This bill ensures that no matter where a  
            consumer decides to apply for coverage there is a defined  
            process in place as to next steps, should they need to appeal  
            a decision.  The author states that this bill also includes an  
            informal resolution process, as specified by the ACA to avoid  
            going to hearing when possible.

           2)BACKGROUND  .  The ACA increases access to health insurance  
            beginning in 2014 through a coordinated system of "insurance  
            affordability programs," including Medicaid, CHIP, APTCs for  
            coverage provided through new Exchanges, and optional  
            state-established BHPs.  It also provides for coordinated,  
            streamlined enrollment processes for these programs.   
            Beginning in 2014, the ACA expands Medicaid eligibility to a  
            new "adult group" and collapses most existing eligibility  
            categories into three broad groups: parents, pregnant women,  
            and children under age 19.  The "adult group" includes all  
            non-pregnant individuals ages 19 to 65 with household incomes  
            at or below 133% FPL.  (The law includes a five percentage  
            point of FPL disregard making the effective limit 138% FPL).   
            The Supreme Court ruling on the ACA,  National Federation of  
            Independent Business v. Sebelius  , 132 S. Ct. 2566 (2012),  
            maintained the adult Medicaid expansion, but limited the DHHS  
            Secretary's authority to enforce it as mandatory on the  
            states, effectively making implementation of the expansion a  
            state choice.  The Supreme Court left the requirements for  
            streamlining and simplification of enrollment for subsidized  
            coverage, as well as the individual mandate intact.  As  
            required by the ACA, Medicaid financial eligibility for most  
            groups will be based on MAGI, as defined in the Internal  
            Revenue Code.  The rule generally adopts MAGI household income  
            counting methods, eliminating various income disregards  
            currently used by states.  The Centers for Medicare & Medicaid  
            Services (CMS) guidelines also generally align "family size"  
            in the current Medicaid rules with the MAGI definition of  
            "household" and provides household composition rules for  
            individuals, such as non-tax filers, who are not addressed by  
            MAGI methods.  Certain groups are exempt from use of MAGI;  
            their financial eligibility will continue to be determined  
            using existing Medicaid rules.  Eligibility for the insurance  
            affordability programs at the Exchange will begin with a MAGI  
            screen.  If an individual is not found eligible for a MAGI  
            group, the state must collect necessary information and  
            determine eligibility under all other Medicaid eligibility  








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            categories (i.e., MAGI-exempt groups, such as disability) and  
            potential eligibility for APTC in an Exchange.  Each state  
            will be required to establish timeliness and performance  
            standards for determining eligibility subject to an outer  
            limit timeliness standard of 45 days for non-disability based  
            eligibility determinations and 90 days for disability-based  
            determinations.  States are also required, to the maximum  
            extent possible, to rely on electronic data matches with  
            trusted third party sources to verify information provided by  
            applicants.  

          State Medicaid agencies are to enter into one or more agreements  
            with an Exchange and other insurance affordability programs to  
            coordinate eligibility determinations and enrollment.  The  
            state Medicaid agency must ensure that any individual who is  
            determined ineligible for Medicaid is screened for potential  
            eligibility for benefits available through an Exchange and  
            promptly transfer the electronic account of individuals  
            screened as potentially eligible to the Exchange.  States also  
            have the option to enter into an agreement with an Exchange to  
            make final determinations of eligibility for APTCs for  
            Exchange coverage.  With regard to Exchange determinations of  
            Medicaid eligibility, states can enter into agreements to  
            either have the Exchange make final Medicaid eligibility  
            determinations or have the Exchange make assessments of  
            potential Medicaid eligibility and transfer accounts to the  
            Medicaid agency for final determination.

           3)The California Exchange  .  The California Exchange was  
            established in 2010 by AB 1602 (John A. P�rez), Chapter 655,  
            Statutes of 2010 and SB 900 (Alquist), Chapter 659, Statutes  
            of 2010.  Through the Exchange, now called Covered California,  
            people with incomes above Medi-Cal up to 400% FPL are eligible  
            for APTCs and those up to 250% FPL are also eligible for Cost  
            Sharing Reductions.  The ACA requires states to have a single  
            streamlined application for Exchange subsidies, their Medicaid  
            programs, and their CHIP programs.  Exchanges will not be  
            insurers but will provide eligible individuals and small  
            businesses with access to QHPs in a comparable way.   
            California has established Covered California, as a  
            state-based exchange that is operating as an independent  
            government entity with a five-member Board of Directors.

          The California Healthcare Eligibility, Enrollment and Retention  
            System (CalHEERS) is a procurement conducted jointly by the  








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            Exchange, the department of Health Care Services (DHCS), and  
            MRMIB to build the Information Technology system to support  
            the consumer application and enrollment process at the  
            Exchange.  Following extensive review and stakeholder comment  
            and input, Accenture was hired through a solicitation process  
            for the design, development, and deployment of CalHEERs.  The  
            portal will offer eligibility determinations for both Medi-Cal  
            and federally subsidized Covered California coverage through  
            the Exchange.  It will allow enrollment through multiple  
            access points including mail, phone, and in-person  
            applications.  It is guided by a "no wrong door" policy that  
            is intended to ensure the maximum number of Californians  
            obtain coverage appropriate to their needs.  Eligibility and  
            enrollment functions will be released in September of 2013 in  
            order to begin enrollment by October 2013, effective January  
            1, 2014.  The CalHEERS business functions include interfacing  
            with the Medi-Cal eligibility data system.  It will also have  
            the capacity to be a secure interface with federal and state  
            databases in order to obtain and verify information necessary  
            to determine eligibility.  

          AB 1602 and SB 900 created the structure and basic duties of the  
            Exchange but did not specify particulars of an appeals process  
                                                                        when consumers disagreed with an eligibility determination by  
            the Exchange.  AB 1602 stated that the Exchange should develop  
            an appeals process once federal guidance was issued.  At  
            recent Exchange Board meetings Covered California discussed  
            their intent to promulgate eligibility and enrollment  
            regulations and has issued an initial draft.  The section on  
            appeals is currently "reserved."  The legislation authorizing  
            the Exchange gave it emergency regulatory authority until  
            January 1, 2016.

           4)Federal regulations  .  In addition to having a streamlined  
            eligibility and enrollment application system, the ACA and its  
            implementing regulations require states to have coordinated  
            notice and appeal procedures.  CMS issued proposed regulations  
            governing exchanges on January 22, 2013 and requested comments  
            be submitted by February 13, 2013.  These proposed regulations  
            covered, among other things, fair hearing and appeals  
            processes for Medicaid and Exchange eligibility and enrollment  
            appeals.  An individual is not eligible for APTCs if they are  
            eligible for Medi-Cal and eligibility for APTCs starts exactly  
            where eligibility for Medi-Cal ends.  The preamble notes that  
            the proposed regulations are intended to maximize coordination  








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            of appeals involving the different insurance affordability  
            programs and minimize burden on consumers and states.   
            Specifically, it proposes that the Medicaid agency treat an  
            appeal of a determination of eligibility for enrollment in a  
            QHP in the Exchange and for APTC or cost-sharing reductions as  
            a request for a fair hearing of the denial of Medicaid.  The  
            preamble further states that this is intended to avoid the  
            need for an individual to request multiple appeals.  The major  
            options the proposed regulations leave up to states is: a)  
            whether and which entity to designate as an "exchange appeals  
            entity;" b) what entity issues the combined notices and (3)  
            whether and which entity should engage in an informal  
            resolution process to try to resolve the case before it  
            reaches the hearing.  States that exercise the option to  
            delegate authority to conduct Medicaid fair hearings to an  
            Exchange must give the individual the option to opt for a fair  
            hearing before the Medicaid agency.  Furthermore, the preamble  
            makes clear the same due process rights apply when delegated  
            to the Exchange and the Medicaid agency would continue to  
            exercise appropriate oversight authority and take corrective  
            actions if necessary.  The proposed regulations also require,  
            to ensure coordination across the entire eligibility,  
            enrollment and appeals process, that a Medicaid application is  
            automatically reinstated if an individual is found potentially  
            ineligible for Medicaid and files an appeal related to the  
            determination or their eligibility for enrollment in a QHP,  
            for APTC or cost-sharing reductions and reinstatement would be  
            effective as of the date the application was initially  
            received.  

           5)DUE PROCESS AND MEDI-CAL FAIR HEARINGS.   The right to an  
            administrative fair hearing stems from the Due Process Clause  
            of the US Constitution as interpreted by the US Supreme Court  
            in  Goldberg v. Kelly  , 397 U.S. 254 (1970) (Goldberg v. Kelly).  
             Federal law requires that the hearing be conducted at a  
            reasonable time, date, and place, after adequate notice, and  
            by an impartial official who was not directly involved in the  
            initial determination of the action in question.  Medi-Cal  
            hearings are heard by Administrative Law Judges (ALJ) from the  
            State Hearings Division of the DSS.  The hearings are held  
            during regular business hours, in at least one location per  
            county.  During the hearing, the claimant must be allowed to  
            present witnesses, evidence, arguments, and confront and  
            cross-examine adverse witnesses.  Medi-Cal hearings include  
            giving testimony under oath and submitting evidence into the  








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            record.  The process is designed to be fair to unrepresented  
            laypersons and is therefore more relaxed than a formal court  
            proceeding.  Formal rules of evidence do not apply, but  
            evidence is admitted "if it is the sort of evidence on which  
            responsible persons are accustomed to rely in the conduct of  
            serious affairs."  The issues are limited to those reasonably  
            related to the request for a hearing, as well as any that both  
            sides have agreed to prior to or at the hearing.

          After a fair hearing, a decision will be sent to the claimant  
            and their representative.  The hearing decision must be in  
            writing and completed within 90 days of the fair hearing  
            request.  It can be based only on the evidence presented at  
            the hearing.  The decision must summarize the facts, identify  
            the regulations supporting the decision, and inform the  
            individual of the reason for the decision and the right to  
            request a rehearing or judicial review.  The decision issued  
            by the ALJ in a Medi-Cal hearing is a proposed decision, which  
            within 75 days is filed with the Director of DHCS who reviews  
            the proposed decision.  The proposed decision is adopted,  
            changed, or set for further hearing.  If the Director takes no  
            action within 30 days of receiving the proposed decision, it  
            is deemed adopted.  If the Director decides the matter  
            differently, that decision is served on the claimant and the  
            county.  If the decision is favorable to the claimant or if  
            the agency decides in his or her favor prior to the hearing,  
            the county must comply with the decision within 30 days.  If  
            applicable, corrective payments must be made retroactive to  
            the date that the incorrect action was taken.  If the decision  
            rules against the claimant, the county can stop aid  
            immediately.  The state may also recover the costs of  
            continued benefits or of "aid paid pending" from the  
            beneficiary.  However, the counties rarely pursue these  
            claims.  If the claimant loses at the fair hearing level, she  
            or he has two options. First, within 30 days of receiving the  
            ALJ's proposed decision, she or he may request a rehearing.   
            The second option after receiving an adverse decision is to  
            ask for judicial review, by filing a petition in the Superior  
            Court within one year after receiving the Director's final  
            decision.

           6)SUPPORT  .  Western Center on Law and Poverty (WCLP), sponsor of  
            this bill, writes in support that the ACA requires a new  
            seamless and coordinated eligibility and enrollment system for  
            Medi-Cal, the Exchange, and AIM.  DHCS and the Exchange are  








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            working to realize this vision - overseeing the building of  
            CalHEERS to be the online application for public health  
            coverage programs as well as providing for in-person, phone,  
            and mail application venues.  Just as the application  
            processes must be coordinated, federal law also requires that  
            notices and appeals for the Exchange, "MAGI Medi-Cal," and AIM  
            be coordinated.  According to WCLP, federal regulations, also  
            require that Exchange appeals conform to Medicaid fair hearing  
            requirements.  WCLP argues that legislation is needed to  
            specify those notice and appeals procedures.  WCLP further  
            states that while Covered California is working on eligibility  
            and enrollment regulations which it has the authority to  
            promulgate under its authorizing legislation, it feels  
            something as important as due process rights belong in  
            statute.  Moreover, because the appeals process for the new  
            combined application affects both Medi-Cal and AIM in addition  
            to the Exchange, that Medi-Cal and AIM notices and appeals  
            should not be governed by Exchange regulations.  The National  
            Health Law Program (NHeLP) writes in support that the  
            requirements of due process are well-established.  NHeLP  
            points out that notice and the right to a fair hearing upon  
            denial of a Medicaid application are of course required by the  
            due process provisions of the Constitution under the Supreme  
            Court's ruling in Goldberg v. Kelly.  NHeLP further states  
            that the ACA requires a new seamless and coordinated  
            eligibility and enrollment system for Medicaid and the  
            Exchange.  In addition, in keeping with the fundamental due  
            process rights outlined above, recently proposed federal  
            Medicaid and Exchange regulations have laid-out clear  
            requirements for integrated notices and a well-coordinated  
            appeals system.  Because both Medicaid and the Exchange  
            (including the tax subsidies and cost sharing reductions) will  
            be utilizing the new MAGI rules, the impact of determining  
            eligibility for the Medi-Cal program will directly impact  
            Exchange coverage, as an applicant cannot be eligible for tax  
            credits in the Exchange if he/she is Medi-Cal eligible.   
            According to NHeLP, this significant overlap requires a highly  
            coordinated, and preferably integrated, notice and appeals  
            system that is provided by this bill.  Disability Rights  
            California, Health Access, the 100% Campaign,  
            California/Nevada Community Action Partnership, the Asian Law  
            Alliance, California Advocates for Nursing Home Reform, and  
            the Coalition of California Welfare Rights Organizations also  
            write in support of this bill because of the coordinated  
            notices that are important to avoid confusion, use of the same  








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            fair hearing process as currently used for Medi-Cal,  
            provisions allowing an informal resolution, expedited appeals,  
            and the ability to retain coverage pending an appeal.  

           7)RELATED LEGISLATION .  

             a)   AB 2 X1 (Pan) and SB 2 X1 (Ed Hernandez) enact  
               substantially similar provisions to implement the ACA  
               insurance provisions related to health insurance regulated  
               under the Insurance Code and the Health and Safety Code,  
               respectively.  Ties both bills together so that they both  
               have to be enacted. 

             b)   AB 1 X1 (John A. P�rez) and SB 1 X1 (Ed Hernandez and  
               Steinberg) implement various provisions of the ACA  
               regarding Medi-Cal eligibility and program simplification  
               including the use of MAGI and expansion of eligibility in  
               the Medi-Cal program.  

             c)   SB 3 X1 (Ed Hernandez) requires Covered California to  
               establish a "bridge" plan product by contracting with  
               Medi-Cal managed care plans for individuals losing Medi-Cal  
               coverage (for example, because of an increase in income),  
               the parents of Medi-Cal children, and individuals with  
               incomes below 200% FPL.

             d)   SB 18 (Ed Hernandez) establishes legislative intent to  
               enact legislation to reform the individual health care  
               coverage market consistent with the ACA.  

             e)   SB 28 (Ed Hernandez and Steinberg) implements various  
               provisions of the ACA regarding Medi-Cal eligibility and  
               program simplification including the use of the MAGI and  
               expansion of eligibility in the Medi-Cal program.  

             f)   AB 50 (Pan) requires DHCS to establish a process to  
               implement the ACA provision that allows hospitals to make a  
               preliminary determination of a person's eligibility for  
               Medi-Cal, requires DHCS to revise the existing process used  
               for Medi-Cal enrollees to choose a managed care plan,  
               requires DHCS, in consultation with the Exchange, and  
               stakeholders, establish a new more coordinated process that  
               is consistent with the ACA and allows applications for  
               renewal of a person's Medi-Cal eligibility to be  
               streamlined by prepopulating the form with existing  








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               available information.  

           8)PREVIOUS LEGISLATION  . 

             a)   AB 43 (Monning) of 2012 would have expanded Medi-Cal  
               coverage to persons with income that does not exceed 133%  
               FPL, effective January 1, 2014 and would have required a  
               transition plan for persons enrolled in a Low Income Health  
               Program (LIHP).  AB 43 died on the Senate Inactive File.  

             b)   SB 677 (Ed Hernandez) of 2012 would have required DHCS  
               to implement the provisions of the ACA relating to  
               eligibility and benefits in the Medi-Cal program.  SB 677  
               died on the Assembly Inactive File.  

             c)   SB 1487 (Ed Hernandez) of 2012 would have required DHCS  
               to extend Medi-Cal eligibility to youth who were formerly  
               in foster care and who are under 26 years of age, subject  
               to federal financial particiapation being available and to  
               the extent required by federal law.  SB 1487 would have  
               also made legislative findings and declarations regarding  
               the ACA, stated legislative intent to ensure full  
               implementation of the ACA, and to enact into state law any  
               provision of the ACA that may be struck down by the US  
               Supreme Court.  SB 1487 was held on the Senate  
               Appropriations Committee suspense file.  

             d)   AB 342 (John A. P�rez), Chapter 723, Statutes of 2010,  
               enacts the LIHP and Coverage Expansion and Enrollment  
               Projects to provide health care benefits to uninsured  
               adults up to 200% of the FPL, at county option through a  
               Medi-Cal waiver demonstration project.  

             e)   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 requires that an individual would have the option  
               to apply for state health programs through a variety of  
               means.  

             f)   AB 1595 (Jones) of 2010, would have required DHCS to  








                                                                  AB 617
                                                                  Page  16

               expand Medi-Cal eligibility to individuals with family  
               income up to 133% of FPL without regard to family status by  
               January 1, 2014.  AB 1595 died on suspense in the Assembly  
               Appropriations Committee.

             g)   AB 1602 establishes the Exchange as an independent  
               public entity to purchase health insurance on behalf of  
               Californians with incomes of between 100% and 400% FPL and  
               employees of small businesses.  Clarifies the powers and  
               duties of the board governing the Exchange relative to the  
               administration of the Exchange, determining eligibility and  
               enrollment in the Exchange, and arranging for coverage  
               under qualified carriers.  

             h)   SB 900 establishes the Exchange.  Requires the Exchange  
               to be governed by a five-member board, as specified.  

           REGISTERED SUPPORT / OPPOSITION  :  

           Support 
           
          Western Center on Law and Poverty (sponsor)
          100% Campaign
          Asian Law Alliance
          California Advocates for Nursing Home Reform
          California/Nevada Community Action Partnership
          Children Now
          Children's Defense Fund California
          Children's Partnership
          Coalition of California Welfare Rights Organizations
          Disability Rights California
          Greenlining Institute
          Health Access California
          National Health Law Program

           Opposition 
           
          None on file.
          
          Analysis Prepared by  :    Marjorie Swartz / HEALTH / (916)  
          319-2097 












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