BILL ANALYSIS                                                                                                                                                                                                    Ó



                                                                  AB 975
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          Date of Hearing:  April 2, 2013

                            ASSEMBLY COMMITTEE ON HEALTH
                                 Richard Pan, Chair
             AB 975 (Wieckowski and Bonta) - As Amended:  March 21, 2013
           
          SUBJECT  :  Health facilities community benefits.

           SUMMARY  :  Revises California's nonprofit community benefits  
          requirements to include multispecialty clinics and narrows the  
          activities that constitute community benefits, creates a  
          definition of charity care, requires the Office of Statewide  
          Health Planning and Development (OSHPD) to develop a  
          standardized methodology for calculating community benefits,  
          calculate the value of community benefits for submitting  
          entities, and to issue civil penalties for noncompliance with  
          filing requirements.  Provides a rebuttable presumption that  
          hospitals are organized as for profit if operating revenue  
          exceeds 10% of operating expenses during the immediate preceding  
          fiscal year.  Specifically,  this bill  :  

          1)Expands the entities to which OSHPD charges fees to support  
            the California Health Data and Planning Fund to include all  
            licensed clinics.

          2)Repeals existing hospital community benefits law, and  
            establishes new hospital community benefits requirements.

          3)Requires private nonprofit hospitals and nonprofit  
            multispecialty clinics to provide community benefits to the  
            community.  Requires, by January 1, 2015, these entities to  
            develop, in collaboration with the community, a community  
            benefits statement, a description of the process for approval  
            of the statement by the hospital's or clinic's governing  
            board, and a community health needs assessment using available  
            public health data.  Requires by April 1, 2015 the development  
            of a community benefits plan to achieve specified outcomes.   
            Requires the community health needs assessment to be made  
            available to the public for review and comment prior to  
            approval.  Requires the assessment to be filed with OSHPD and  
            updated at least every three years.

          4)Establishes specifications for the community benefits plan  
            such as a list of services categorized by charity care; other  
            community benefits, including community health improvement  








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            services and community benefit operations, health professions  
            education, subsidized health services, research and  
            contributions to community groups; community 
          building activities targeting underserved and vulnerable  
            populations; an estimate of the economic value of the  
            community benefits that the private nonprofit hospital or  
            nonprofit multispecialty clinic intends to provide; a  
            description of the intended impact on health outcomes  
            attributable to the plan, including short- and long-term  
            measurable goals and objectives; the name and title of the  
            individual responsible for implementing the plan; and, the  
            names of individuals on the private nonprofit hospital's or  
            nonprofit multispecialty clinic's governing board.

          5)Establishes definitions, including the following:
             a)   Charity care means the unreimbursed cost to a private  
               nonprofit hospital or nonprofit multispecialty clinic of  
               providing services to the uninsured, or underinsured, as  
               well as providing funding or otherwise financially  
               supporting any of the following:
               i)     Health care services or items on an inpatient or  
                 outpatient basis to a financially qualified patient with  
                 no expectation of payment;
               ii)    Health care services or items provided to a  
                 financially qualified patient through other nonprofit or  
                 public outpatient clinics, hospitals, or health care  
                 organizations with no expectation of payment;
               iii)   Community benefits, provided that the provision,  
                 funding, or financial support of those benefits is  
                 demonstrated to reduce community health care costs.   
                 Community benefits means vaccination programs and  
                 services for low income families, chronic illness  
                 prevention programs and services, nursing and caregiver  
                 training provided without assessment of fees or payment  
                 of tuition, home-based health care programs for  
                 low-income families, or programs for low-income families.  
                  Low-income families means families or individuals with  
                 income less than or equal to 350% of the federal poverty  
                 level (FPL).
             b)   Charity care does not include:
               i)     Uncollected fees or accounts written off as bad  
                 debt; 
               ii)    Care provided to patients for which public or  
                 private grant funds pay for any of the charges for the  
                 care; 








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               iii)   Contractual adjustments in the provision of health  
                 care services below the amount identified as gross  
                 charges or "chargemaster" rates by the health care  
                 provider; 
               iv)    Any amount over 125% of the Medicare rate for the  
                 health care services or items provided on an inpatient or  
                 outpatient basis;
               v)     Any amount over 125% of the Medicare rate for  
                 providing funding, or otherwise financially supporting  
                 health care services or items with no expectation of  
                 payment provided to financially qualified patients  
                 through other nonprofit or public outpatient clinics,  
                 hospitals, or health care organizations; and, 
               vi)    The cost to a nonprofit hospital of paying a tax or  
                 other governmental assessment.

          6)Applies this bill's provisions to private nonprofit acute care  
            hospitals operated or controlled by a nonprofit corporation,  
            as defined, that has been determined exempt from taxation  
            under the US Internal Revenue Code (IRC), and nonprofit  
            multispecialty clinics, defined in existing law as clinics  
            operated by a nonprofit corporation exempt from federal income  
            taxation, as specified, under section 501 of the IRC that  
            conduct medical research and health education and provide  
            health care to its patients through a group of 40 or more  
            physicians and surgeons, who are independent contractors  
            representing not less than 10 board-certified specialties, and  
            not less than two-thirds of whom practice on a full-time basis  
            at the clinic.  Exempts district hospitals and rural general  
            acute care hospitals.

          7)Permits a private nonprofit hospital or nonprofit  
            multispecialty clinic to also report on bad debts and Medicare  
            shortfalls, although these shall not be calculated or reported  
            as community benefits.

          8)Requires the draft community benefits plan to be available to  
            the public in hard copy and on the website no later than 30  
            days prior to its adoption by the governing board.  Requires,  
            after April 1, 2015, every two years, a private nonprofit  
            hospital or nonprofit multispecialty clinic to revise and  
            submit its community benefit plan to OSHPD no later than 120  
            days after the end of the hospital's or clinic's fiscal year.   
            Permits a person or entity to file comments on a community  
            benefit plan with OSHPD.  








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          9)Permits a private nonprofit hospital or nonprofit  
            multispecialty clinic, under the common control of a single  
            corporation or another entity, to file a consolidated plan if  
            the plan addresses services in all of the categories listed in  
            4) above to be provided by each hospital or clinic under  
            common control of the corporation or entity.  

          10)Requires OSHPD to develop and adopt regulations to prescribe  
            a standardized format for community benefits plans; a  
            standardized methodology for estimating the economic value of  
            community benefits; to the maximum extent possible, conform to  
            Internal Revenue Service (IRS) reporting standards and other  
            data elements required by State law; and, post on its Internet  
            website annually a private nonprofit hospital or nonprofit  
            multispecialty clinic's IRS Form 990 or its successor form.

          11)Requires OSHPD to provide technical assistance to nonprofit  
            hospitals and nonprofit multispecialty clinics.  Requires  
            OSHPD to make public on its Internet Website hospital and  
            clinic community health needs assessments and community  
            benefits plans and any comments received regarding those  
            assessments and plans.  Requires OSHPD to annually calculate  
            and make public the total value of community benefits provided  
            by private nonprofit hospitals and nonprofit multispecialty  
            clinics that report pursuant to this bill.

          12)Authorizes OSHPD to assess a civil penalty against any  
            private nonprofit hospitals or nonprofit multispecialty clinic  
            that fails to comply with this bill in the amount of $100 a  
            day for delays in filing and not more than $5,000 for not  
            using approved accounting systems.

          13)Updates Cal-Mortgage requirements to include the community  
            assessment required by this bill as an activity an applicant  
            must demonstrate participation in, if appropriate.

          14)Revises the property taxation welfare exemption for hospitals  
            in the Revenue and Taxation Code to establish a rebuttable  
            presumption that during the preceding fiscal year a hospital  
            with operating revenues, exclusive of gifts, endowments and  
            grants-in-aid that exceed operating expenses by an amount  
            equivalent to 10% of those operating expenses is organized or  
            operated for profit.  Presumes hospitals with operating  
            revenues, exclusive of gifts, endowments, and grants-in-aid,  








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            with operating revenues equivalent to less than 10% of  
            operating expenses, are organized or operated as not for  
            profit.  Provides that this provision is declaratory of  
            existing law.

           EXISTING LAW  :  

          1)Establishes OSHPD, and requires each organization that  
            operates, conducts, or maintains a health facility to make and  
            file with OSHPD certain specified reports, including a  
            Hospital Discharge Abstract Data Record that currently  
            includes 19 elements of data per admission that are required  
            to be included.

          2)Requires, under California's hospital community benefits law,  
            licensed health facilities, as specified, and freestanding  
            ambulatory surgery clinics to be charged a fee established by  
            OSHPD to support health data and planning purposes and any  
            other health related-programs administered by OSHPD. 

          3)Requires each not-for-profit licensed general acute care  
            hospital, acute psychiatric hospital, or special hospital that  
            is owned by a corporation that has been determined to be  
            exempt from taxation under the IRC to complete a community  
            needs assessment evaluating the health needs of the community  
            serviced by the hospital that includes, but is not limited to,  
            a process for consulting with community groups and local  
            government officials in the identification and prioritization  
            of community needs that the hospital can address directly, in  
            collaboration with others.  

          4)Requires the entities in 3) above to submit annually its  
            community benefits plan to OSHPD not later than 150 days after  
            the hospital's fiscal year ends.  Exempts from the community  
            benefits law hospitals serving children that do not receive  
            direct payment and small and rural hospitals. 

          5)Establishes required elements for hospital community benefit  
            plans such as:
             a)   Mechanisms to evaluate the plan's effectiveness;
             b)   Measurable objectives to be achieved within specified  
               timeframes; and, 
             c)   Community benefits categorized by medical care services,  
               other benefits for vulnerable populations, other benefits  
               for the broader community, health research, education, and  








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               training programs, and nonquantifiable benefits.

          6)Defines, for purposes of planning and reporting under the  
            community benefit law, community benefits as a hospital's  
            activities intended to address community needs and priorities  
            primarily through disease prevention, and improvement of  
            health status including but not limited to health care  
            services rendered to vulnerable populations, charity care and  
            the unreimbursed cost of providing services to the uninsured,  
            underinsured, and those eligible for Medi-Cal, Medicare,  
            California Children's Services Program, or county indigent  
            programs, as well as health care cost containment and other  
            activities.

          7)Requires under California's fair pricing policies, hospitals,  
            as a condition of licensure, to maintain an understandable,  
            written policy regarding discount payments for financially  
            qualified patients, as well as an understandable, written  
            charity care policy.  Requires each hospital to provide to  
            OSHPD a copy biennially on January 1, or when a significant  
            change is made, of its discount payment policy, charity care  
            policy, and eligibility procedures for those policies, the  
            review process, and the application for charity care or  
            discounted payment programs.  Requires OSHPD to make this  
            information available to the public.

          8)Provides that uninsured patients or patients with inadequate  
            insurance with family income at or below 350% FPL are eligible  
            to apply for hospital's charity care or discount payment  
            policies.

          9)Requires any extended payment plans offered by a hospital to  
            assist patients eligible under the hospital's charity care  
            policy, discount payment policy, or any other policy adopted  
            by the hospital for assisting low-income patients with no  
            insurance or high medical costs in settling outstanding past  
            due hospital bills, to be interest free.

          10)   Permits the hospital extended payment plan to be declared  
            no longer operative after the patient's failure to make all  
            consecutive payments due during a 90-day period.  Requires a  
            reasonable attempt to be made to contact the patient by phone  
            and in writing that the extended payment plan may become  
            inoperative.









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          11)   Establishes emergency physician fair pricing policies for  
            uninsured or patients with high medical costs who are at or  
            below 350% FPL.

          12)   Exempts certain clinics from licensure including clinics  
            operated by a nonprofit corporation exempt from federal income  
            taxation, as specified, under section 501 of the IRC that  
            conduct medical research and health education and provide  
            health care to its patients through a group of 40 or more  
            physicians and surgeons, who are independent contractors  
            representing not less than 10 board-certified specialties, and  
            not less than two-thirds of whom practice on a full-time basis  
            at the clinic.  

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

           COMMENTS  :

           1)PURPOSE OF THIS BILL  .  According to the author, this bill will  
            create a standard definition of charity care that includes a  
            refined definition of community benefits for nonprofit  
            hospitals.  This bill will clarify existing law concerning the  
            rebuttable presumption that a hospital with revenues in excess  
            of 10% of their operating expenses is operated as a for profit  
            institution.  Further, this bill will clearly define what  
            constitutes charity care, which must be a direct provision of  
            care, not promotional activities or cost containment, as  
            currently provided within the guidelines of "community  
            benefit," and will improve reporting requirements for greater  
            public transparency in how hospitals meet their charity care  
            obligation, with rigorous financial penalties for hospitals  
            that fail to meet reporting requirements. 

           2)BACKGROUND .  In a report prepared by the Senate Office of  
            Research (SOR) for an August 15, 2012 hearing of the Senate  
            Select Committee on Charity Care and Nonprofit Hospitals,  
            about 247 of California's 387 private hospitals may be  
            eligible for certain tax exemptions due to their nonprofit  
            status in exchange for providing various community benefits,  
            such as charity care.  However, these community benefits are  
            not uniformly defined or measured.  This ambiguity makes it  
            challenging to hold hospitals accountable for the special tax  
            benefits they receive and determine if they are providing  
            meaningful community benefits.  Furthermore, some studies show  








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            many investor-owned hospitals and public hospitals provide  
            charity care and other community benefits similar to or  
            greater than their nonprofit counter parts.  The SOR points  
            out that the California Legislative Analyst's Office (LAO), in  
            an analysis of the Charity Care Act of 2012 indicates that  
            there is currently no uniform definition of charity care nor a  
            requirement in State or federal law for nonprofit hospitals to  
            provide a certain amount of charity care or community benefit  
            in order to maintain their tax exempt status.  According to  
            the LAO, of the private hospitals in California, about 30% are  
            for-profits and about 70% are nonprofits. The for-profit  
            hospitals pay corporate income taxes to the state. Nonprofit  
            hospitals are exempt from State corporate income taxes, local  
            sales taxes, and property taxes. The tax exemptions are  
            intended to allow nonprofit hospitals to use the funds that  
            would have been paid in taxes to provide patient care, invest  
            in their facilities and equipment, and implement other  
            measures that would be beneficial to their delivery of  
            healthcare services.  The SOR report indicates that  
            controversy exists in how charity care and community benefits  
            are quantified.  Some hospitals use a cost accounting  
            methodology while others use a ratio that converts a  
            hospital's listed charges to the actual cost of the services  
            provided.  SOR also reports that in 2008 the IRS revised Form  
            990 in an effort to provide transparency and accountability  
            and keep pace with changes in the law with regard to the tax  
            exempt sector.  The new form requires nonprofit hospitals to  
            report their bad debt expenses and Medicare shortfalls, but  
            excludes them from counting these as community benefits.

              a)   State Audits  .  The California State Auditor (Auditor)  
               has conducted two audits on the topic of tax exemption and  
               nonprofit hospitals: one in December of 2007 and another in  
               August of 2012.  The 2007 report found that inconsistent  
               data obscured the economic value of the benefit to  
               communities and made recommendations to the Franchise Tax  
               Board, which have largely been implemented, to more closely  
               monitor tax exempt status.  The audit recommended to the  
               Legislature the adoption of statutory requirements that  
               prescribe a mandatory format and methodology for tax-exempt  
               nonprofit hospitals to follow when presenting community  
               benefits in their plans, and an amendment in law to require  
               income and property tax exemptions for nonprofit hospitals  
               to be based upon nonprofit hospitals providing a certain  
               level of community benefits.  Neither of those  








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               recommendations has been adopted.  

             The 2012 audit found that State agencies cannot use the  
               community benefits plans to justify the tax-exempt status  
               of nonprofit hospitals; neither federal nor State law  
               requires nonprofit hospitals to deliver a specific amount  
               of community benefits to qualify for tax exemptions; with  
               no standard methodology, hospitals use different methods to  
               calculate and report the cost of uncompensated health care  
               services; there are differences in the income levels used  
               when nonprofit hospitals determine whether patients qualify  
               for charity care, so a family who qualifies at one  
               hospitals may not qualify at another; that the impact on  
               prices when changes in ownership or operation of nonprofit  
               hospitals could not be determined but that the amount of  
               uncompensated care generally did not change; and that OSHPD  
               adequately monitors hospitals' submissions or required  
               data, but cannot penalize those hospitals that fail to  
               submit the required community benefits plans.  The Auditor  
               recommended again that the Legislature consider amending  
               State law to include requirements about the amounts of  
               community benefits if it intends to tie the  hospitals' tax  
               exempt status to the amount of community benefits provided;  
               define a methodology in state law for calculating community  
               benefits each hospital delivers or direct OSHPD to develop  
               regulations that define such a methodology; and, allow  
               OSHPD to assess penalties to hospitals that do not submit  
               required community benefits plans.

              b)   Other States  .  As reported by SOR, Texas was the first  
               state to pass legislation requiring a level of community  
               benefit relative to hospital resources, community needs,  
               and tax exemption benefits.  Many states have definitions  
               of charity care, including New York, Pennsylvania,  
               Washington, and Wisconsin.  In June 2012, Illinois approved  
               a law which requires hospitals to provide charity care to  
               low-income populations, and another law, which requires  
               nonprofit hospitals to provide charity care that meets or  
               exceeds their estimated property tax liability to maintain  
               their tax exempt status, and broadens the definition of  
               charity care beyond care to indigent.  In 2012, Washington  
               State required tax-exempt hospitals to make their federally  
               required community needs assessment and implementation  
               strategies widely available to the public.  In addition,  
                                       they must be evidence based or subject to evaluation.  








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             c)   Charity Care Act of 2012  .  This initiative would have  
               required certain nonprofit hospitals to provide a minimum  
               amount of charity care equal to at least 5% of net patient  
               revenue, impose new data reporting requirements on certain  
               nonprofit hospitals, impose new administrative  
               responsibilities on the Attorney General (AG) and give the  
               AG authority to oversee and enforce the provisions of the  
               measure.  This measure would have gone into effect January  
               1, 2013, and been repealed on December 31, 2017.  The  
               initiative would have exempted nonprofit hospitals that are  
               part of an integrated nonprofit health system or part of a  
               safety-net nonprofit health system as defined by the  
               measure (Dignity Health and Kaiser Permanente) and it did  
               not include multispecialty clinics. According to the LAO,  
               about 36% of the State's nonprofit hospitals would have  
               been exempted from the requirements of the initiative.  On  
               May2, 2012, the Los Angeles Times reported that the Service  
               Employees International Union dropped the initiative along  
               with another health care initiative as part of an agreement  
               with California Hospital Association.

              d)   LAO Analysis  .  The LAO indicates that the Charity Care  
               Act of 2012 could have resulted in both costs and savings  
               to State and local governments, depending on how the  
               hospitals subject to the measure responded to it.  Their  
               analysis finds that most of the nonprofit hospitals subject  
               to the measure would have to increase the amount of charity  
               care they provide in order to meet its requirements.  To  
               offset the additional costs of providing greater amounts of  
               charity care, hospitals subject to the measure could employ  
               a mix of different strategies. 

              e)   ACA  .  According to SOR, the federal Affordable Care Act  
               (ACA) generally mirrors much of California's existing state  
               requirements for nonprofit hospitals.  These new provisions  
               require nonprofit hospitals to:
               i)     Conduct a community-health needs assessment at least  
                 once every three taxable years and adopt an  
                 implementation strategy to meet the community needs  
                 identified through this assessment;
               ii)    Establish, implement, and widely publicize a  
                 financial assistance policy that must indicate the  
                 eligibility criteria for financial assistance and whether  
                 such assistance includes free or discounted care.  The  








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                 policy must indicate the billing practices and  
                 calculations for patients receiving this discounted care;  
                 and,
               iii)   Limit their billing, collection activities, and  
                 charges directed to uninsured patients and require them  
                 to make reasonable efforts to determine eligibility for  
                 financial assistance before engaging in extraordinary  
                 collection efforts. 

               The ACA also includes new reporting requirements.   
               Nonprofit hospitals are required to report to the IRS the  
               results of the community needs assessment and if all  
               identified needs are not addressed, they are required to  
               provide the reasons why.  Hospitals also must submit  
               audited financial statements to the IRS.  These reporting  
               requirements are in addition to the preexisting  
               requirements of Form 990 and schedule H.  Failure to comply  
               makes hospitals subject to an excise tax penalty of $50,000  
               and the loss of their federal tax exemption.

              f)   Multispecialty clinics  .  This bill applies to nonprofit  
               multispecialty clinics which this bill defines as clinics  
               operated by a nonprofit corporation exempt from federal  
               income taxation, as specified, under section 501 of the IRC  
               that conduct medical research and health education and  
               provide health care to its patients through a group of 40  
               or more physicians and surgeons, who are independent  
               contractors representing not less than 10 board-certified  
               specialties, and not less than two-thirds of whom practice  
               on a full-time basis at the clinic.  This bill's sponsor,  
               the California Nurses Association (CNA) provided a  
               background paper which indicates that these clinics started  
               as physician owned medical foundations enacted into  
               existence in the 1980's and that in the 1990's more of  
               these organizations have become affiliated with or owned by  
               hospitals. 

              g)   Welfare exemption  .  The welfare exemption refers to  
               section 214 of the Revenue and Taxation Code where property  
               used exclusively for religious, hospital, charitable, or  
               scientific purposes, which is owned and operated by  
               nonprofit organizations, is exempt from property taxation.   
               The welfare exemption is co-administered by the State Board  
               of Equalization (Board) and County Assessors.  The Board  
               determines if an organization is eligible for exemption and  








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               issues an Organizational Clearance Certificate (OCC) to  
               qualifying organizations.  An OCC remains valid unless  
               revoked by the Board.  The County Assessor determines  
               whether the organization's property qualifies for the  
               exemption, but an exemption may not be granted unless the  
               organization holds a valid OCC.  According to a March 30,  
               2012 review of OCC holders, conducted by the Board,  
               property may be considered exclusively used for hospital  
               purposes if it is owned and operated by a qualifying  
               nonprofit organization and if it is exclusively used to  
               provide support services for the hospital.  The review  
               includes nonprofit multispecialty clinics.  

               The Board reviewed 174 hospital organizations, and of these  
               32 identified ownership and operation of one or more  
               outpatient clinics, child psychiatric service clinics  
               and/or multispecialty clinics.  The Board's review found  
               that 24 organizations had surplus revenue in at least one  
               year from 2005 through 2008.  Surplus revenue is when  
               operating revenue exceeds operating expenses by more than  
               10%.  According to the Board, the percentage by which net  
               operating expenses exceed 10% of operating expenses for  
               those entities with surplus revenue ranged from less than  
               1% to 165%.  Seven of the 24 entities have multispecialty  
               clinics.  The Board determined that the surplus revenue was  
               used for acceptable purposes including debt retirement,  
               expansion of plant and facilities, and reserve for  
               operating cost contingencies.

              h)   Rideout Hospital Foundation v. County of Yuba (1992) 8  
               Cal.App.4th 24  .  In this case, Yuba County denied a  
               nonprofit hospital with surplus revenue the welfare  
               exemption for two tax years.  The hospital brought action  
               against the County to recover property taxes paid under  
               protest.  The trial court granted summary judgment in favor  
               of the hospital finding that a nonprofit hospital that  
               earns surplus revenues in excess of 10% for a given tax  
               year can still qualify for the welfare exemption.  The  
               Court of Appeal affirmed the trial court's decision.  The  
               Court of Appeal held that the legislative history of the  
               provision indicates that it was not intended to deny  
               exemption to a nonprofit organization earning excess  
               revenues for debt retirement, facility expansion, or  
               operating cost contingencies, but merely to require a  
               hospital earning such excess revenue to affirmatively show  








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               that, in fact, it is not operated for profit and that it  
               meet other statutory conditions for invoking the exemption.

              i)   Rebuttable presumption  .  According to this bill's  
               sponsor, the rebuttable presumption is consistent with  
               existing law, but in the event that a local tax assessor  
               questioned a covered entity's continuing entitlement to a  
               property tax exemption (in the event that its revenues  
               exceeded the 10% mark), the entity would be required to  
               demonstrate that it is not operated for profit and meets  
               the other statutory conditions for invoking the exemption.  
               By pairing this clarification with changes to the Health &  
               Safety Code that would standardize definitions of "charity  
               care" and "community benefits," local tax assessors will be  
               in a position to determine whether the property in question  
               is being used for operation of a legitimately exempt  
               activity and not hanging onto revenues beyond an amount  
               reasonably necessary to accomplish the exempt, charitable  
               purpose.   

           3)SUPPORT  .  The sponsor, CNA, writes in support of this bill  
            that it seeks to define charity care for nonprofit hospitals  
            and refine what is considered "community benefits" to ensure  
            California's nonprofit hospitals are fulfilling their mission  
            statements and providing community benefits in exchange for  
            their tax-exempt status.  CNA adds that in 2010, more than  
            seven million Californians lacked health insurance and that  
            even with so many in need of health care, California's  
            nonprofit hospitals benefited $1.8 billion from their  
            tax-exempt status.  According to CNA for the most recent year  
            data are available, half of California's nonprofit hospitals  
            provided 2.46% or less of their operating costs on charity,  
            well below the federal standard of 5% needed to maintain tax  
            exempt status.  Nonprofit hospitals accumulated $4.5 billion  
            in profits that same year, close to half of that by two of  
            California's largest hospital chains Sutter Health and Kaiser  
            Permanente.  The lack of charity care provided by these  
            hospitals has a significant impact on many of California's  
            struggling cities and counties.  Supporters, including CNA,  
            the Greenling Institute, and the California Rural Legal  
            Assistance Foundation all support the rebuttable presumption  
            where hospitals and multispecialty clinics with revenue over  
            10% of their operating expenses the previous year are  
            for-profit entities.  Health Access California (HAC), Consumer  
            Federation of California, and Consumer Watchdog all write in  








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            support of the definitions in this bill for what constitutes  
            charity care and community benefits.  The California  
            Professional Firefighters state that the existing property tax  
            exemption for health facilities bear little relationship to  
            the level of charity care they provide, that California's  
            counties, cities, and special districts, like fire districts,  
            rely on tax revenue to fund critical public services to the  
            communities they serve.  HAC argues that hospitals use the  
            term "uncompensated care," which means bad debt where  
            collection agencies, some owned by nonprofit hospital systems,  
            pursue the uninsured to the point of bankruptcy and seizure of  
            their homes; therefore, defining charity care as care for  
            which there is no expectation of payment, hospitals would no  
            longer be able to claim bad debt as charity care.

           4)OPPOSITION  .  Scripps Health writes in opposition to this bill  
            that it would impose a new and unrealistic definition of  
            charity care, creating a "guilty until proven innocent" burden  
            on hospitals that report an operating margin over 10%.   
            Scripps Health and the California Chamber of Commerce claim  
            this bill inappropriately changes the basis for a nonprofit  
            hospital's nonprofit status; that instead of deeming such  
            status if a hospital's margin does not exceed 10%, this bill  
            establishes a rebuttable presumption that a hospital is  
            organized for profit if it exceeds 10% in any one year.   
            Kaiser Permanente adds that the rebuttable presumption  
            provision in this bill will prove to be extremely unclear and  
            could have the unintended consequences of being interpreted  
            differently by different parties.  Kaiser Permanente states  
            that the very narrow definition of community benefit in this  
            bill, could exclude critically important programs for  
            low-income, uninsured, and indigent Californians.  The  
            California Right to Life Committee, Inc. (CRLC, Inc.) also in  
            opposition to this bill writes that "it would remove the  
            understanding of the corporal charitable works of mercy from  
            its biblical underpinnings to one of government mandated work  
            for the merely and presumably human good of the community  
            making these organizations answerable to the state and not to  
            their higher calling of faith and mercy."  CRLC, Inc. adds  
            that this bill is an attempt to turn hospitals and other  
            health care facilities into appendages of the state, requiring  
            reporting and very likely invasions of privacy through data  
            collection on individuals' lifestyles who receive assistance  
            from hospitals.  CRLC, Inc. writes that family planning and  
            abortion services would be included, as they are not  








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            specifically excluded.

           5)RELATED LEGISLATION  .  AB 1382 (Committee on Health) makes  
            technical changes to terms used in the reporting of health  
            data information by specified health facilities to OSHPD.

           6)PREVIOUS LEGISLATION  . 

             a)   AB 1503 (Lieu), Chapter 445, Statutes of 2010, requires  
               emergency physicians who provide emergency medical services  
               in a hospital to provide discounts to uninsured patients,  
               establishes limits on the expected payment for emergency  
               medical services as specified, limits debt-collection  
               activities, and requires hospitals to include a written  
               description of the hospital discount policy.

             b)   AB 2942 (Kuehl) of 2008 would have implemented the State  
               Auditor's 2007 recommendation for a standardized format and  
               methodology to be used when presenting community benefit  
               information, among other requirements.

             c)   SB 350 (Runner), Chapter 347, Statutes of 2007, requires  
               the submission of hospital charity care and  
               discount-payment policies to OSHPD.

             d)   AB 774 (Chan), Chapter 755, Statutes of 2006,  
               establishes Hospital Fair Pricing Policies, which requires  
               every hospital to offer reduced rates to uninsured and  
               underinsured patients who may have low or moderate income,  
               and to provide policies that clearly state the  
               qualifications for free care and discounted payments.

             e)   AB 1045 (Frommer), Chapter 532, Statutes of 2005,  
               revises the Payers' Bill of Rights to require hospitals to  
               provide information about their financial assistance and  
               charity care policies, as well as contact information for a  
               hospital employee or office to obtain additional  
               information.

             f)   SB 610 (Machado) of 2005 would have clarified existing  
               law regarding hospitals entitled to claim the welfare  
               exemption for property tax purposes by indicating a  
               hospital organization is deemed to be organized or operated  
               for profit if operating revenues exceed operating expenses  
               by more than 10%. Governor Schwarzenegger vetoed SB 610,  








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               indicating that "This bill financially penalizes non-profit  
               hospitals which are increasing reserves to invest in  
               important and necessary charitable activities  including  
               purchasing state-of-the-art technology to improve the  
               quality of patient care, complying with costly seismic  
               safety mandates, and expanding facilities to increase  
               access to care for low-income uninsured Californians.  This  
               bill provides that non-profit hospitals whose operating  
               revenues exceed operating expenses by more than ten percent  
               would be rebuttably presumed to be operated for profit for  
               tax purposes, regardless of whether the reinvestment of  
               excess dollars is for legitimate charitable activities.   
               Existing law provides adequate safeguards against the  
               inappropriate use of any excess operating revenues.   
               Hospitals should be encouraged to increase investment in  
               our communities rather than penalized for it.  For this  
               reason, I cannot support this measure."

             g)   SB 24 (Ortiz) of 2005 would have established charity  
               care and reduced payment policies and requirements as a  
               condition for hospitals to maintain their tax-exempt  
               status.

             h)   AB 232 (Chan) of 2004 was substantially similar AB 774  
               and would have required each hospital to develop a self-pay  
               policy specifying how the hospital determines prices to be  
               paid by self-pay patients, as defined, and limits these  
               prices for patients below specified income levels.  AB 232  
               would also have established limits on billing and  
               collection activities of hospitals and their agents.  AB  
               232 died on the Senate Floor.

             i)   SB 379 (Ortiz) of 2004 would have required every  
               hospital to have a charity care policy and to provide that  
               policy to patients and would have required OSHPD to develop  
               a uniform charity care application to be used by all  
               hospitals.  Governor Schwarzenegger vetoed SB 379, stating  
               that "the voluntary guidelines must be given time to be  
               implemented and reviewed" and that it was his expectation  
               that "all hospitals in the state uphold their important  
               commitment to the voluntary guidelines and that they are  
               applied evenly, consistently and without hesitation."

             j)   AB 1627 (Frommer), Chapter 582, Statutes of 2003,  
               establishes the Payers' Bill of Rights, which generally  








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               requires certain hospitals to provide written or electronic  
               copies of their chargemaster, as specified.

             aa)  SB 697 (Torres), Chapter 812, Statutes of 1994, requires  
               nonprofit hospitals to conduct community needs assessments  
               and develop community benefit plans and submit those plans  
               to OSHPD.

           7)DOUBLE REFERRAL  .  This bill has been double referred.  Should  
            this bill be approved in the Committee on Health it will be  
            referred to the Committee on Revenue and Taxation.

           8)POLICY COMMENTS  .
             a)   This bill adds additional clinics to those licensed  
               clinics subject to the OSHPD fee associated with data  
               submission.  Presumably this provision is intended to  
               include nonprofit multispecialty clinics in the fee payment  
               process.  However, nonprofit multispecialty clinics are not  
               licensed and based on the current provisions of this bill  
               would continue to be excluded from the fee requirement.   
               The author may wish to amend this bill to address this  
               issue.
             b)   Based on the review of OCCs conducted by the Board it  
               appears that community benefits requirements would apply to  
               nonprofit multispecialty clinics by virtue of their  
               relationship to the nonprofit hospital so it may not be  
               necessary to single them out as does this bill. 

           REGISTERED SUPPORT / OPPOSITION  :  

           Support 
           
          California Nurses Association (sponsor)
          CA Conference Board of the Amalgamated Transit Union
          CA Conference of Machinists
          California Domestic Workers Coalition
          California Labor Federation
          California Professional Firefighters
          California Rural Legal Assistance Foundation
          California Tax Reform Association
          California Teamsters Public Affairs Council
          Consumer Federation of California
          Consumer Watchdog
          Engineers and Scientists of CA
          Greenlining Institute








                                                                  AB 975
                                                                  Page  18

          Health Access California
          Professional and Technical Engineers
          United Food & Commercial Workers Western States Council
          UNITE-HERE, AFL-CIO
          Utility Workers Union of America

           Opposition 
           
          Adventist Health
          Alliance of Catholic Health Care
          California Chamber of Commerce
          California Right to Life Committee, Inc.
          Kaiser Permanente
          Scripps Health
           
          Analysis Prepared by  :    Teri Boughton / HEALTH / (916) 319-2097