BILL ANALYSIS                                                                                                                                                                                                    Ó



                                                                  AB 1180
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          ASSEMBLY THIRD READING
          AB 1180 (Pan)
          As Amended May 2, 2013
          2/3 vote. Urgency 

           HEALTH              18-0        APPROPRIATIONS      16-1        
           
           ----------------------------------------------------------------- 
          |Ayes:|Pan, Ammiano, Atkins,     |Ayes:|Gatto, Harkey, Bigelow,   |
          |     |Bonilla, Bonta, Chesbro,  |     |Bocanegra, Bradford, Ian  |
          |     |Gomez,                    |     |Calderon, Campos, Eggman, |
          |     |Roger Hernández,          |     |Gomez, Hall, Rendon,      |
          |     |Lowenthal, Maienschein,   |     |Linder, Pan, Quirk,       |
          |     |Mansoor, Mitchell,        |     |Wagner, Weber             |
          |     |Nazarian, Nestande,       |     |                          |
          |     |V. Manuel Pérez, Wagner,  |     |                          |
          |     |Wieckowski, Wilk          |     |                          |
          |     |                          |     |                          |
          |-----+--------------------------+-----+--------------------------|
          |     |                          |Nays:|Donnelly                  |
          |     |                          |     |                          |
           ----------------------------------------------------------------- 
           SUMMARY  :  Makes inoperative because of the federal Patient  
          Protection and Affordable Care Act (ACA) several provisions in  
          existing law that implement the health insurance laws of the  
          federal Health Insurance Portability and Accountability Act of  
          1996 (HIPAA) and additional provisions that provide former  
          employees rights to convert their group health insurance  
          coverage to individual market coverage without medical  
          underwriting.  Specifically,  this bill  :  

          1)Makes several provisions in existing law inoperative on  
            January 1, 2014, including laws related to:  a) HIPAA and  
            conversion policies comparative benefit matrices pursuant to  
            AB 1401 (Thomson), Chapter 794, Statutes of 2002; b)  
            Conversion to nongroup coverage when the group policy has been  
            terminated by the employer including requirements on carriers  
            without individual market products to offer the most popular  
            health maintenance organization (HMO) model plan or the most  
            popular preferred provider organization (PPO) plan with the  
            greatest number of enrolled individuals for its type of plan  
            as of January 1 of the prior year, as reported to the  
            California Department of Managed Health Care (DMHC) or the  
            California Department of Insurance (CDI) under the same cost  








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            sharing terms and conditions (AB 1401); c) Requirements that  
            at least once a year a carrier permit an individual who has  
            been covered for at least 18 months in an individual market  
            plan to transfer to another plan or policy with equal or  
            lesser benefits without medical underwriting pursuant to AB  
            2889 (Frommer), Chapter 826, Statutes of 2006; d) Requirements  
            included in HIPAA conformity law pursuant to SB 265 (Speier),  
            Chapter 810, Statutes of 2000; e) Conversion policy for  
            employees or members with insurance on an expense-incurred or  
            service basis, other than for a specific disease or for  
            accidental injuries only whose coverage has been terminated  
            pursuant to SB 1846 (Russell), Chapter 1186, Statues of 1982;  
            and, f) Except with regard to specified provisions, on and  
            after January 1, 2014, that are applicable only to  
            grandfathered individual health plan contracts previously  
            issued to federally eligible defined individuals.

          2)Repeals 1) if the federal mandate on individuals to purchase  
            insurance is repealed or amended to no longer apply to the  
            individual market.

          3)Requires carriers to issue notices to individuals affected by  
            this bill informing them of changes in insurance laws  
            beginning January 1, 2014.  Requires uniform model notices to  
            be adopted by CDI and DMHC no later than September 1, 2013,  
            and exempts the departments from Administrative Procedure Act  
            for purposes of adopting the model notices.

           EXISTING LAW  :  

          1)Establishes DMHC to regulate health plans under the Knox-Keene  
            Health Care Services Plan Act of 1975 in the Health and Safety  
            Code; CDI to regulate health insurers under the Insurance  
            Code; and, the Exchange to compare and make available through  
            selective contracting with health plans and health insurance  
            for individual and small business purchasers as authorized  
            under the ACA.  

          2)Defines a grandfathered health plan as having the same meaning  
            as that term is defined in the ACA.  Federal law defines a  
            grandfathered health plan as any group health plan or health  
            insurance coverage to which Section 1251 of the ACA applies  
            (in general, coverage that existed as of March 23, 2010, which  
            permits new enrollment only for new employees or dependents).








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           FISCAL EFFECT  :  According to the Assembly Appropriations  
          Committee, minor costs, less than $100,000, to CDI and DMHC to  
          develop the model notice.  Negligible costs for the provisions  
          to make HIPAA and conversion laws inoperative and subsequently  
          operative if specified ACA changes occur.  If those ACA changes  
          occur, this bill's provisions along with many other new state  
          laws will need to be reevaluated for potential cost issues.

           COMMENTS  :  Health plans and health insurance companies believe  
          that in a post ACA world where there is guaranteed issue,  
          renewability, community rating, prohibitions on preexisting  
          condition exclusions, and many other protections made available  
          through the ACA, that these HIPAA and conversion requirements on  
          carriers are no longer necessary.  However, according to the  
          author, these carriers also requested, and in agreement, the  
          Governor insisted that certain federal ACA protections must be  
          "tied back" to federal law, so that if those ACA provisions are  
          repealed, so too would the major provisions of California's  
          implementing ACA legislation.  The author states that given  
          these circumstances, this bill is intended to make inoperative  
          the HIPAA and conversion provisions until such time as those ACA  
          protections are repealed, if ever.  Additionally, some  
          individuals who are in grandfathered plans will be able to stay  
          in such plans until, and unless, they choose nongrandfathered  
          ACA compliant coverage.  For those individuals in HIPAA PPO  
          plans, the rating protections in existing California law must be  
          adjusted in the event that the Major Risk Medical Insurance  
          Program is shut down, as is a possibility at some point in the  
          future because of the new ACA protections.   

          The California Association of Health Plans and the Association  
          of California Life & Health Insurance Companies support this  
          bill because this bill resolves an important state-federal  
          conformity issue by helping avoid a situation where health  
          plans, absent this legislation, would be required to sell  
          federal HIPAA and state conversion products that are out of  
          compliance with the ACA.  Health Access California believes this  
          bill would continue to protect consumers.

          This bill contains an urgency clause, allowing this bill to take  
          effect immediately upon enactment.










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           Analysis Prepared by  :    Teri Boughton / HEALTH / (916) 319-2097  
                                                       FN: 0000607