BILL ANALYSIS                                                                                                                                                                                                    



                                                                  SB 138
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          Date of Hearing:  June 25, 2013

                           ASSEMBLY COMMITTEE ON JUDICIARY
                                Bob Wieckowski, Chair
                    SB 138 (Hernandez) - As Amended:  May 28, 2013

           SENATE VOTE  :  26-11
           
          SUBJECT  :  Confidentiality of Medical Information 

           KEY ISSUE  :  Should a dependent covered by another person's  
          insurance policy be permitted to protect the confidentiality of  
          treatments for "sensitive services" by, among other things,  
          requesting that insurance communications be sent to A designated  
          address? 

           FISCAL EFFECT  :  As currently in print this bill is keyed fiscal.  


                                      SYNOPSIS

          As part of the expansion of health care coverage under the  
          Affordable Care Act (ACA), it is anticipated that a growing  
          number of young adults will avail themselves of the opportunity  
          to be covered under a parent's health insurance policy until the  
          age of 26.  As such, according to the author, ACA will expand  
          the number of young adults who may have compelling reasons for  
          not revealing to the primary policy holder (typically a parent,  
          guardian, or spouse) that they have been treated for certain  
          "sensitive services," such as mental health treatment, drug or  
          alcohol treatment, testing for HIV or other sexually-transmitted  
          diseases, or reproductive health services.  Some studies suggest  
          that young people, in particular, may forgo these preventive and  
          even life-saving services for fear that a parent or spouse, as  
          the notified policy holder, may find out.  Federal law already  
          provides some protections in this regard by, for example,  
          permitting a dependent, under certain circumstances, to request  
          that insurance communications be sent to an alternate address.   
          This bill would codify a somewhat stronger version of those  
          federal protections into state law.  In order to address  
          opposition concerns about the precise mechanism by which an  
          insured dependent would communicate his or her preferences about  
          how the insurer should handle communications about sensitive  
          services, the author has agreed, in principle, to take the  
          amendments listed at the end of this analysis.  However, because  








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          of timing issues, these amendments will be formally taken in the  
          Assembly Health Committee, which will hear this bill if it moves  
          out of this Committee.  The following analysis reflects the  
          proposed amendments. While the proposed amendments appear to  
          address the most significant concerns raised by the opposition,  
          it is not clear whether the amendments will remove the  
          opposition entirely. 

           SUMMARY  :  Requires a health care service plan or health insurer  
          to take certain steps to protect the confidentiality of an  
          insured individual's medical information.  Specifically,  this  
          bill  :   

          1)Declares the intent of the Legislature to incorporate HIPAA  
            standards into state law and to clarify standards for  
            protecting the confidentiality of medical information in  
            insurance transactions. 

          2)Requires a health care service plan or health insurer  
            (insurer), to the extent permitted by federal law, to take the  
            following steps to protect the confidentiality of an insured  
            individual's medical information as follows:

             a)   For an insured individual who is insured as a dependent  
               on another person's insurance policy, an insurer shall not  
               send insurance communications relating to sensitive  
               services, as defined, unless a communication is required by  
               federal law. 
             b)   Where a communication  is  required by federal law, the  
               insurer must do one of the following:

                  (1)       Send the required information to the insured  
                    individual in compliance with a confidential  
                    communications request that was sent to the insurer by  
                    the insured. 
                  (2)       Where the insurer has not received a  
                    confidential communication request, it must send the  
                    required communication to the insured individual and  
                    may send it to the address furnished by the policy  
                    holder. 

          3)Requires the insurer, for communications pertaining to  
             non  -sensitive services, to comply with a confidential  
            communications request or a nondisclosure request from an  
            insured individual who states that disclosure of medical  








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            information will endanger the individual, and specifies that  
            the insurer shall not require an explanation as to the basis  
            for the insured individual's statement that disclosure will  
            endanger the individual. 

          4)Provides that a confidential communications request or  
            nondisclosure request is deemed received by the insurer within  
            24 hours of electronic transmission or 72 hours of posting by  
            first class mail. 

          5)Authorizes a provider of health care to make arrangements with  
            the insured individual for the payment of benefit cost-sharing  
            arrangements and to communicate those arrangements to the  
            insurer. 

          6)Prohibits an insurer from conditioning enrollment in the plan  
            or eligibility for benefits upon a waiver of the right to  
            submit a confidential communication request or nondisclosure  
            request.

          7)Defines "confidential communications request" to mean a  
            request submitted by an insured individual to an insurer that  
            insurance communications be communicated by a specific method,  
            such as by telephone, e-mail, or in a covered envelope rather  
            than a postcard, or to a specific mail or e-mail address or  
            specific telephone number, as designated by the insured  
            individual. 

          8)Defines "nondisclosure request" to mean a written request to  
            withhold insurance communications that includes the insured  
            individual's name and address, a description of the medical or  
            other information that shall not be disclosed, the identity of  
            persons from whom information shall be withheld, and the  
            contact information for additional information or  
            clarification necessary to satisfy the request. 

           EXISTING LAW  :

          1)Sets forth, under the federal Health Insurance Portability and  
            Accountability Act (HIPAA), various privacy protections for  
            patients' personal health information and generally provides  
            that a covered entity (health plan, health care provider, and  
            health care clearing house) may not use or disclose protected  
            health information except as specified or as authorized by the  
            patient in writing.  (45 C.F.R. Sec. 164.500 et seq.)  








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          2)Prohibits, under the California Confidentiality of Medical  
            Information Act (CMIA), health care providers, health care  
            service plans, or contractors from sharing medical information  
            without the patient's written authorization, subject to  
            certain mandatory and permissive exceptions.  (Civil Code  
            Section 56.10 et seq.) 

          3)Permits, under the Patient Protection and Affordable Care Act  
            (ACA), adult children under the age of 26 to be insured as  
            dependents on a health insurance policy held in another  
            person's name.  (Public Law 111-148, 124 Stat. 119.) 

          4)Defines "medical information" to mean any individually  
            identifiable information, in electronic or physical form, in  
            possession of or derived from a provider of health care,  
            health care service plan, pharmaceutical company, or  
            contractor regarding a patient's medical history, mental or  
            physical condition, or treatment.  Existing law defines  
            "individually identifiable" to mean that the medical  
            information includes or contains any element of personal  
            identifying information sufficient to allow identification of  
            the individual, such as the patient's name, address,  
            electronic mail address, telephone number, or social security  
            number, or other information that, alone or in combination  
            with other publicly available information, reveals the  
            individual's identity.  (Civil Code Section 56.05(g).)

          5)Permits minors to consent to certain health care treatments,  
            including sexual and reproductive health services, drug  
            treatment, and mental health treatment or counseling services  
            if, in the opinion of the attending professional, the minor is  
            mature enough to participate intelligently in treatment or  
            counseling services.  (Health & Safety Code Sections 123115  
            and 124260; Civil Code Section 56.11(c)(1); Family Code  
            Sections 6924-6929.)

          6)Requires an insurer that makes a decision to deny or contest a  
            health care service claim to provide a notice explaining the  
            decision to both the insured who received services and to the  
            health care provider that provided the services.  The notice  
            shall advise both the provider and the insured that either may  
            seek a review of the contested or denied claim, and the notice  
            shall include the address, Internet Web site address, and  
            telephone number of the unit that performs this review  








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            function.  (Insurance Code Sections 10169(b) and 10123.13(a).)  


          7)Requires, under federal law, a health care service plan to  
            provide the insured with a notice that sets forth the specific  
            reasons for a denial of benefits and to inform the insured of  
            his or her right to receive a full and fair review of the  
            denial by the plan administrator.  Specifies that, at a  
            minimum, the denial notice must include the specific reason or  
            reasons for the denial; a specific reference to pertinent plan  
            provisions upon which a denial is based; and information on  
            the steps to be taken if the insured wishes to submit a claim  
            for review.  (29 USC Section 1133; 29 CFR Section 2560.503-1  
            (f).) 

           COMMENTS  :  The Patient Protection and Affordable Care Act (ACA),  
          as signed into law by President Obama in 2010, is part of a  
          larger joint federal-state effort to expand health care coverage  
          to the uninsured in a variety of new ways, from permitting small  
          businesses and persons who are not provided insurance through  
          their employers to seek low-cost insurance through an exchange,  
          to requiring all persons to obtain health care insurance either  
          through an employer, an exchange, or the private market.  

          Less publicized perhaps, is the ACA provision extending coverage  
          to more people by permitting young people to remain on the  
          insurance policies of their parents or guardians for a longer  
          period of time.  Specifically, by January 1, 2014, ACA requires  
          all plans and insurers that offer dependent insurance coverage  
          to make that coverage available until the adult child reaches  
          the age of 26.  Both married and unmarried children will qualify  
          for this coverage, even if they have another offer of coverage  
          through an employer.  While this new policy will usefully extend  
          health insurance to young adults - one of the most underinsured  
          segments of the population - the author and sponsor believe that  
          it will also pose new challenges for protecting the  
          confidentiality of medical information.  Specifically, many  
          covered minor or adult children may have compelling reasons for  
          not revealing to the primary policy holder (typically a parent,  
          guardian, or spouse) that they have received treatment for  
          certain "sensitive services," such as mental health treatment,  
          drug or alcohol treatment, testing for HIV or other  
          sexually-transmitted diseases, or reproductive health services.   
          The author and sponsor contend that young adults, in particular,  
          sometimes forgo these preventive and even life-saving services  








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          for fear that a parent or spouse, as the notified policy holder,  
          might find out.  For example, a 2012 study by the Guttmacher  
          Institute lends support to this contention by finding that: 

              [P]rivacy issues are often seen as a potentially significant  
              impediment for minors and young adults seeking care.  
              Confidentiality can be a factor when individuals are seeking  
              a broad range of health care services. For example, privacy  
              concerns may be a barrier to individuals seeking substance  
              abuse treatment or mental health care. Lack of  
              confidentiality may lead individuals experiencing intimate  
              partner violence to hesitate in seeking care for fear their  
              abuser may be alerted . . . Despite the widespread  
              recognition of the importance of maintaining patient  
              confidentiality, billing and insurance claim -most notably  
              the practice of sending explanation of benefits forms (EOBs)  
              to a policyholder whenever care is provided under his or her  
              policy- routinely violate confidentiality for anyone, often  
              a minor or a young adult, insured as a dependent on someone  
              else's policy?Obviously, when the patient is the  
              policyholder, no issue arises from this disclosure.   
              However, when the patient is insured as a dependent on  
              someone else's policy-such as that of a parent, spouse or  
              domestic partner-disclosure of protected health information  
              is possible, with potentially serious consequences.  
              (Guttmacher Institute, Confidentiality for Individuals  
              Insured as Dependents: A Review of State Laws and Policies,  
              (July 2012) pp. 3-4.) 

          The federal Health Insurance Portability and Accountability Act  
          (HIPAA) recognizes the fact that insured dependents may  
          sometimes wish to prevent the unintended disclosure of  
          confidential medical information through insurance  
          communications to the policy holder.  HIPPA's overall purpose is  
          to prohibit covered entities - health plans, health care  
          providers, and health care clearing houses - from disclosing  
          personal health information unless the disclosure is authorized  
          by the patient in writing or is subject to an express statutory  
          exemption.  (45 C.F.R. Sec. 164.500 et seq.)  Of particular  
          relevance to this bill, one provision of HIPAA authorizes  
          insurers to send communications that might contain confidential  
          medical information to alternate addresses or to send them by  
          alternate means, such as to a designated telephone number or  
          e-mail address, as opposed to sending the communication by  
          regular mail to the address of the policy holder.  Under HIPPA,  








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          insurers are required to accommodate "reasonable requests" for  
          these alternate means of communication, but only if the  
          "individual clearly states that the disclosure of all or part of  
          the information could endanger the individual" (45 C.F.R.  
          164.522(b)).  HIPAA also permits patients to request that  
          insurers restrict communications in other ways, for example, by  
          asking that an explanation of benefits not be mailed to certain  
          identified persons.   

          This bill seeks to codify a parallel version of the HIPPA rules  
          into California law.  Specifically,  as proposed to be amended,  
          this bill would require a health care service plan or health  
          insurer to take certain steps when sending insurance  
          communications (including an explanation of benefits) pertaining  
          to "sensitive services" that the insured dependent may have  
          received.  The bill would permit an insured dependent to submit  
          a "confidential communication request" that would, in most  
          instances, require the insurer to send a communication  
          pertaining to a sensitive service to an alternate address or by  
          alternate means.  The bill would also permit an insured  
          dependent to send either a "confidential communication request"  
          or a "non-disclosure request" for any other medical services  
          (i.e. not one of the designated a "sensitive service") if the  
          insured believes that he or she will be endangered by the  
          communication of medical information.   The bill specifies that  
          this statement shall be sufficient by itself, and that the  
          insurer shall not require any further explanation for the reason  
          for the request.  While there would potentially be overlap  
          between the contents of a "confidential communication request"  
          and a "nondisclosure request," the principle difference is that  
          the former merely specifies an alternate address or method of  
          communication, while the latter would request the exclusion of  
          certain kinds of personal or medical information from the  
          content of the communication. 

          The bill defines "sensitive services" to include reproductive  
          health services, mental health services, treatment of sexual  
          assault, testing or treatment for sexually transmitted diseases,  
          and treatment for drug or alcohol abuse.  In an earlier version,  
          this bill would have prohibited an insurer from sending a  
          communication relating to sensitive services provided to a  
          dependent who is under 26 years of age unless that under-26  
          dependent had provided the insurer with prior authorization to  
          send the communication.  Unlike HIPPA rules, which require the  
          insured to initiate contact with the insurer in order to  








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          restrict communications that are otherwise automatically sent,  
          an earlier version of this bill would have required the insured  
          to notify the insurer before the insurer could send anything to  
          any address if the claim was for a "sensitive service."   
          However, an insured who may have no interest in restricting  
          communications would probably not think that he or she would  
          need to affirmatively authorize the insurer to send  
          communications, since this is the normal practice.  As such, the  
          prior authorization requirement would have put the insurer in a  
          quandary: it would be required by federal and state law to send  
          an explanation of benefits whenever it does not pay the full  
          amount of the service, but if the under-26 ensured has not  
          bothered to send either a prior authorization or an alternate  
          address, the insurer would not be able to send any communication  
          to any address.  The insurer would have been compelled to either  
          violate federal or state law requiring a communication, or to  
          violate the provisions of this bill if the insured had not  
          provided a prior authorization or an alternate address.  After  
          several discussions between the author, sponsor, opponents, and  
          Committee staff, the bill as proposed to be amended addresses  
          this mechanical difficulty as follows:

                 If the insured is a dependent on another person's  
               policy, the insurer shall not send a communication relating  
               to sensitive services unless it is required to do so under  
               federal law (that is, where the insurer does not pay the  
               full amount of the service).  If the insurer is required to  
               send a communication under federal law, then the insurer  
               must do one of the following:  if the insured has submitted  
               a confidential communication request, then the insurer must  
               send the communication in compliance with that request; if  
               the insured has not submitted a confidential communication  
               request or alternate address, then the insurer may send the  
               communication to the policy holder.  

                 Where a communication does not pertain to a sensitive  
               service (i.e. any other health care service) the insurer  
               must comply with a confidential communication or  
               nondisclosure request that is submitted by any insured who  
               states that disclosure of medical information will endanger  
               the insured, and the insurer shall not require any further  
               explanation for the insured 's statement. 

          In addition, this measure will specify that any confidential  
          communication or nondisclosure request shall be deemed received  








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          within 24 hours of sending an electronic request and within 72  
          hours of posting a request by first class mail.  The bill would  
          also prohibit an insurer from conditioning eligibility for  
          benefits upon waiver of the right to submit a confidential  
          communication or nondisclosure request. 

          This bill would offer more protection than HIPPA currently does  
          by permitting an insured dependent to request that  
          communications regarding sensitive services be sent to an  
          alternate address or by alternate means, without having to  
          provide a statement that communication will somehow "endanger"  
          the insured, as is required by HIPPA.  However, requests for  
          non-sensitive services under this bill, as under HIPPA, would  
          still require such a statement. 

           ARGUMENTS IN SUPPORT  :  According to the author, "SB 138 will  
          bring clarity to an existing patchwork of state and federal  
          statutes and regulations related to the sharing of patient  
          information in order to protect patient confidentiality for  
          insured dependents accessing services related to sexual and  
          reproductive health, HIV/AIDS, substance abuse and mental health  
          care or any other health care service when disclosure could  
          cause harm."  The author believes that the need for this bill is  
          especially great now that ACA will expand the number of insured  
          dependents who may have valid reasons for not disclosing  
          sensitive medical information to the policy holder.  For  
          example, the author writes that the expansion of coverage under  
          ACA "will exacerbate an existing conflict between two important  
          policies: maintaining appropriate health plan and insurer  
          communications with a policy holder to ensure billing and  
          payment transparency versus protecting patient confidentiality  
          for insured dependents accessing sensitive services like sexual  
          and reproductive health care, mental health services and drug  
          and alcohol abuse treatment.  The ACA will dramatically expand  
          the number of individuals insured as dependents on a health  
          insurance policy held in another person's name.  Dependents  
          covered by a family member's insurance policy are often young  
          people (under the ACA, health plans and insurers are required to  
          offer dependent coverage for children up to age 26) or spouses  
          of the policy holder who may not feel safe revealing that they  
          have received sensitive health care services."  The author  
                                          believes that SB 138, as proposed to be amended, will strike an  
          appropriate balance between potentially conflicting goals of  
          promoting full communication and protecting patient privacy.      









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          According to the California Family Health Council (CFHC), the  
          bill's sponsor, while the expansion of coverage under ACA is "a  
          momentous step forward, individuals covered by a family member's  
          plan are often children, spouses, or domestic partners and may  
          not feel safe or comfortable having their personal and sensitive  
          health information shared with the plan holder."  CFHC contends  
          that breaches in patient confidentiality "often occur through  
          the Explanation of Benefits (EOBs) and other methods of  
          communication generated by health plans and insurers. . . The  
          inability to guarantee confidential access to services can lead  
          to harm," as "some minors and adults may choose not to seek care  
          for sensitive services such as STDs, birth control, drug  
          treatment and mental health services for fear a parent or  
          partner will find out."    CFHC believes that "SB 138 will close  
          loopholes and clarify definitions" in existing state and federal  
          law and thereby "help insured dependents feel safe and  
          comfortable using their private health insurance to assess the  
          health care services they need.  This is good for public health  
          and will help save state dollars."  For substantially the same  
          reasons as those given by CFHC, this bill is supported by  
          several other groups, including ACLU, Planned Parenthood, the  
          California Partnership to End Domestic Violence, the California  
          Primary Care Association, the California National Organization  
          of Women, and several other medical, women's, and child and teen  
          advocacy groups. 

           ARGUMENTS IN OPPOSITION  :  The California Association of Health  
          Plans (CAHP) opposes this bill primarily because of concerns  
          about the mechanics by which an insured would communicate his or  
          her desires to the insurer, as well as practical problems that  
          insurers may face in attempting to honor these requests -  
          especially in light of state and federal laws and regulations  
          that require to send notices whenever the insurer does not cover  
          all of the costs.  CAHP writes: 

             We understand the intent of SB 138 and its focus on  
             protecting the privacy of those receiving defined  
             "sensitive services." However, we do have significant  
             implementation and workability concerns. While the bill  
             offers similar protections already afforded under federal  
             laws, it goes further by creating a new process where  
             dependents under the age of 26 must opt-in before  
             receiving any communications related to sensitive services  
             from their plan.








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             Complying with this proposed law would be difficult  
             because health plans have little initial contact with  
             anyone other than the primary contract holder. Most other  
             communications related to medical services occur at the  
             doctor-patient level that health plans do not control.  
             Additionally, this opt-in process would require plans to  
             invest a considerable amount of time and resources toward  
             upgrading all their IT systems in order to fully comply  
             with this bill.

             We are concerned that health plan premium payers and  
             enrollees, including those covered by Preferred Provider  
             Organizations regulated by the Department of Managed  
             Health Care, will not be receiving important information  
             such as: explanation of benefits forms, scheduling  
             information, notices of denial, as well as notices of  
             contested claims, the appeal rights they may have if a  
             claim has been denied, and the potential financial  
             liability that exists related to the services they have  
             received.

          Given that CAHP's primary opposition appears to concern what  
          it calls the "opt in" requirement - that is, the provisions  
          in an earlier version of the bill that prohibited the insurer  
          from sending any communications pertaining to sensitive  
          services unless the insured had provided prior authorization  
          - it is unclear whether the bill as proposed to be amended  
          will address all of CAHP's concerns.  The bill is opposed by  
          the Association of California Life & Health Insurance  
          Companies (ACLHIC) for the same reasons as those articulated  
          by CAHP, and it is equally unclear whether the proposed  
          amendments will remove ACLHIC's opposition.

          Finally, the SB 138 is opposed by the California Right to  
          Life Committee (CLRC).  First, CLRC argues that the law is  
          "redundant" in that both HIPPA and state law already provide  
          substantially similar privacy protections.  Second, CLRC  
          argues that this bill fails to protect "the conscience rights  
          of policy holders" who may object to their insurance policies  
          being used to fund procedures (such as abortions) to which  
          they are morally opposed.  Finally, CLRC asserts that this  
          bill "allows law enforcement and the medical establishment  
          access to the private health information of minor children,  
          while denying the same information to the parents of the  








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          child."  [NOTE:  Committee staff notes that this criticism  
          may be more aptly applied to existing law, insofar as  
          existing law, in limited situations, permits minors to have  
          certain medical procedures without the consent of a parent or  
          guardian if, in the opinion of the attending medical  
          professional, the minor is mature enough to participate in  
          the treatment, or, in the case of an abortion, if the minor  
          petitions the juvenile court and the court makes specified  
          findings.]
           
          PROPSOSED AMENDMENTS (To be taken in Assembly Health Committee) 

                                    Amendment #1:

              -    On page 3 lines 26-31 delete subdivision (b) and  
               re-letter remaining subdivisions accordingly.  
                                      Amendment #2:

              -    Beginning on page 8 line 35 through page 9 line 26  
               delete SEC. 4 in its entirety and replace with the  
               following. 

           SEC. 4.  Section 56.107 is added to the Civil Code, to read: Line 2  
          56.107.(a)

          (a) Notwithstanding any other law, and to the extent permitted by  
          federal law, a health care service plan or health insurer shall  
          take the following steps to protect the confidentiality of an  
          insured individual's medical information as follows:

          (1 ) For an insured individual who is insured as a dependent on  
          another person's insurance policy, a health care service plan or  
          health insurer shall not send insurance communications relating to  
          sensitive services, except as required by federal law.  Where an  
          insurance communication is required by federal law:

               (A) The health service plan or health insurer must send the  
          required communication to the insured individual in compliance with  
          a confidential communications request received from the insured  
          individual.   

               (B) Where the health service plan or health insurer has not  
          received a confidential communications request, it must send the  
          required communication to the insured individual and may do so at  
          the address furnished by the policy holder. 








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          (2)  For insurance communications not addressed in paragraph (1) of  
          subdivision (a), a health care service plan or health insurer shall  
          comply with a nondisclosure request or a confidential  
          communications request from an insured individual who states that  
          disclosure of medical information will endanger the individual, and  
          shall not require an explanation as to the basis for the insured  
          individual's statement that disclosure will endanger the  
          individual.

          (3)  A confidential communications request or nondisclosure request  
          is deemed received by the health service plan or health insurer  
          within 24 hours of electronic transmission or 72 hours of posting  
          by first class mail.

          (b) Notwithstanding subdivision (a), the provider of health care  
          may make arrangements with the insured individual for the payment  
          of benefit cost sharing and communicate that arrangement with the  
          health care service plan or health insurer.

          (c) A health care service plan or health insurer shall not  
          condition enrollment or coverage in the health plan or health  
          insurance policy or eligibility for benefits upon a waiver of the  
          right to submit confidential communications and nondisclosure  
          requests. 

          REGISTERED SUPPORT / OPPOSITION  :

           Support 
           
          California Family Health Council (sponsor)
          ACCESS Women's Health Justice
          American Civil Liberties Union 
          American Congress of Obstetricians and Gynecologists, District  
          IX (California)
          California Adolescent Health Collaborative 
          California Association of Marriage and Family Therapists
          California National Organization of Women
          California Partnership to End Domestic Violence
          California Primary Care Association
          California Psychological Association  
          California Women's Law Center
          Center on Reproductive Rights and Justice at UC Berkeley School  
          of Law 
          Citizens for Choice








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          Los Angeles Trust for Children's Health
          National Center for Youth Law 
          National Council of Jewish Women 
          National Health Law Program 
          Physicians for Reproductive Health 
          Planned Parenthood
          Privacy Rights Clearinghouse 
          Women's Community Clinic
           
          Opposition 
           
          Association of California Life and Health Insurance Companies 
          California Association of Health Plans 
          California Right to Life Committee

           Analysis Prepared by  :   Thomas Clark / JUD. / (916) 319-2334