BILL ANALYSIS Ó
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Date of Hearing: September 8, 2015
ASSEMBLY COMMITTEE ON HEALTH
Rob Bonta, Chair
ABX2 17
(McCarty) - As Introduced August 27, 2015
SUBJECT: Health insurance: prohibition on health insurance
sales: health care service plans.
SUMMARY: Deletes provisions that a person or entity subject to
regulation under the Knox-Keene Health Care Service Plan Act of
1975 (Knox-Keene Act) is not subject to the jurisdiction of the
California Department of Insurance (CDI). Specifically, this
bill:
1)Repeals existing law providing that a person or entity subject
to regulation under the Knox-Keene Act is not subject to the
jurisdiction of CDI.
2)Prohibits PPOs from being licensed under Knox-Keene.
Specifically, prohibits an entity licensed under the
Knox-Keene Act from offering, marketing, or selling health
insurance, as defined, including a preferred provider
organization (PPO) or other arrangement under which a health
insurer (insurer) pays group benefits for expenses incurred on
the account of hospitalization or medical or surgical aid
pursuant to an amount of benefit provided by the insurance
policy arrangement, as specified.
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3)Repeals existing law applying to Anthem Blue Cross, which
allowed them to operate under Knox-Keene. Specifically,
provides that a nonprofit hospital corporation that
substantially indemnified subscribers and enrollees and was
operating in 1965 under the Insurance Code, as specified, and
which is regulated under Knox-Keene shall enjoy the privileges
under the act that would have been available to it had it been
registered under the Knox-Mills Health Plan Act (Knox-Mills)
and applied for a license under the Knox-Keene Act in 1976.
EXISTING LAW:
1)Establishes the Knox-Keene Act, the body of law governing
health plans in the state, and provides for the licensure and
regulation of health plans by the Department of Managed Health
Care (DMHC).
2)Provides for the regulation of insurers by CDI.
3)Subjects to the jurisdiction of CDI, any person or entity that
provides coverage, whether by direct payment or reimbursement,
for medical, surgical, chiropractic, physical therapy, speech
pathology, audiology, professional mental health, dental,
hospital, or optometric services, and that enters into an
agreement or contract with a PPO or other arrangement under
which a disability insurer pays group insurance benefits for
expenses related to hospitalization or medical or surgical
aid, as specified.
4)Exempts persons or entities subject to licensure under the
Knox-Keene Act from CDI jurisdiction.
5)Defines health insurance as an individual or group disability
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insurance policy that provides coverage for hospital, medical,
or surgical benefits, as specified.
6)Defines a "health care service plan" (plan) as any person who
undertakes to arrange for the provision of health care
services to subscribers or enrollees, or to pay for or to
reimburse any part of the cost for those services, in return
for a prepaid or periodic charge paid by or on behalf of the
subscribers or enrollees.
7)Provides that a nonprofit hospital corporation that
substantially indemnified subscribers and enrollees, and was
operating in 1965 under the Insurance Code, and which is
regulated under the Knox-Keene Act, shall enjoy the privileges
under the act that would have been available to it had it been
registered under Knox-Mills and applied for a license under
Knox-Keene in 1976.
8)Imposes, under the California Constitution, a 2.35% tax on
insurers doing business in California, commonly referred to as
the "gross premiums tax" (GPT), and specifies that the GPT is
in lieu of all other taxes and licenses, with specified
exceptions.
9)Establishes California's Medicaid program, Medi-Cal, through
which eligible low-income individuals receive health care
services.
10)Establishes a sales tax in the amount of 3.9% on MCMC plans,
beginning July 1, 2013 through July 1, 2016, and specifies
that these funds be directed to DHCS for purposes of funding
managed care rates for health care services for children,
seniors, persons with disabilities, and individuals dually
eligible for Medicare and Medi-Cal that reflect the cost of
services and acuity of the population served.
FISCAL EFFECT: This bill has not yet been analyzed by a fiscal
committee.
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COMMENTS:
1)PURPOSE OF THIS BILL. According to the author, we need to
close the loophole that allows any insurer to move their
health insurance products to DMHC to avoid strong consumer
protections oversight of CDI and avoid paying the taxes. The
author states that the added tax revenue will strengthen and
expand Medi-Cal.
2)BACKGROUND.
a) Types of insurance. There are various types of
full-service health coverage plans and policies available
to California consumers today. The two main types of
health plans and policies are:
i) Health maintenance organizations (HMOs), which
provide and arrange for health care for enrollees through
a network of providers. HMOs generally only cover health
services provided by provides in their networks; and,
ii) PPOs, plans in which the health insurer contracts
with a network of medical providers who agree to accept
lower fees and/or to control utilization. Enrollees in a
PPO plan have the option to obtain care from a provider
that is out of the PPO network, but generally pay a
higher share of cost in doing so.
iii) Other types of full-service plans include Point of
Service (POS) plans and Exclusive Provider Organizations
(EPOs). POS plans combine the characteristics of an HMO
and PPO by designating a network of providers for
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enrollees, but also allowing enrollees to go outside of
the network for health care services. EPOs are a network
of providers who have entered into written agreements
with a plan or insurer to provide services to
subscribers. EPO subscribers cannot go outside of the
EPO network for care.
Additionally, specialized health plans are available that
cover only certain types of care. Examples of specialized
plans include dental, vision, behavioral health, and
chiropractic plans.
b) Insurance regulators. Regulation and oversight of
health insurance in California is split between two state
departments - DMHC and CDI. DMHC regulates health plans,
including HMOs and some PPOs. CDI regulates multiple lines
of insurance, including health insurers, generally PPO
plans and traditional indemnity coverage.
Although DMHC and CDI both regulate health plans as health
insurers, providing health coverage, each department
approaches that regulation differently. At the heart of
the difference between health plans and health insurers is
the "promise to pay" versus the "promise to deliver care."
DMHC-licensed plans, arrange for and organize the delivery
of health care and services through contracted or owned
providers and facilities and are required to cover all
medically necessary services. Health insurers protect
against (indemnify) the expense or charges (losses)
associated with illness or injury and typically provide
coverage for defined benefits that may be specifically
limited in the policy, such as number of visits or annual
dollar limits.
DMHC currently licenses all of the four types of health plans
previously described. The majority of plans regulated by
DMHC are HMOs. However, DMHC also regulates several full
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service PPOs, including Anthem Blue Cross and Blue Shield
of California. DMHC also regulates several specialized PPO
plans such as Delta Dental and Vision Service Plan. CDI
primarily regulates PPOs and EPOs.
According to the California Health Benefits Review Program
(CHBRP), in 2015, it is estimated that 23.4 million
Californians will be enrolled in state-regulated health
insurance, 21.3 million of which will enroll in
DMHC-regulated full-service plans. According to CDI, in
2014, it had 1.7 million insureds in major medical plans,
down from 2.6 million from 2013. DMHC reports that in 2014
it had approximately 2.6 million enrollees in Blue Shield
and Blue Cross full-service PPOs and EPOs. This number can
be expected to rise due, in part, to the fact that DMHC has
licensed three new PPOs, and one EPO which began enrollment
in 2015.
c) Disparities between the Knox-Keene Act and the Insurance
Code. In recent years, efforts have been made to bring
parity between the Knox-Keene Act and the Insurance Code
with regard to consumer protections, particularly with the
implementation of the ACA and accompanying efforts to apply
its insurance market reforms across all markets. Through
the regulatory process, the Insurance Commissioner recently
established rules regarding provider networks and timely
access requirements, two hallmarks of the Knox-Keene Act.
However, disparities in consumer protections between the
two bodies of law remain. Below is a description of some
of the key differences:
i) Balance billing prohibitions for emergency services.
The Knox-Keene Act provides that an enrollee will not be
liable to the provider for any fees owed it by their
plan. This prohibition protects enrollees and
subscribers from being caught in the middle of disputes
between plans and providers. In addition, pursuant to
existing regulations, balance billing for emergency
services is defined as an "unfair billing pattern" and is
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therefore illegal under the Knox-Keene Act. In addition,
the California Supreme Court in Prospect Medical Group v.
Northridge Emergency Medical Group held that "billing
disputes over emergency care must be resolved solely
between the emergency room doctors, who are entitled to a
reasonable payment for their services, and the HMO, which
is obligated to make that payment. Emergency room
doctors may not bill the patient for the disputed
amount." This decision applies solely to emergency
providers who have provided services to Knox-Keene
Act-regulated plan enrollees.
The Insurance Code prohibits in-network providers from
charging or collecting copayments that exceed what is
calculated as a part of the provider's contracted rate,
and, with regard to out-of-network emergency services,
prohibits copayments or coinsurance to exceed amounts
required for in-network emergency care. However, it does
not provide a prohibition on balance billing the patient
for emergency services such as that applied to
DMHC-regulated plans.
ii) Definition of "basic health care services". The
Knox-Keene Act requires plans to contract to provide to
enrollees basic health care services defined as:
physician services; hospital inpatient services and
ambulatory care services; diagnostic laboratory and
diagnostic and therapeutic radiologic services; home
health services; preventive health services; emergency
health care services, as specified; and, hospice care.
These services are further defined in implementing
regulations.
The Insurance Code does not contain such a definition.
This is relevant because, although the Patient Protection
and Affordable Care Act (ACA) requires individual and
small group policies to cover 10 categories of essential
health benefits (EHBs), this requirement does not apply
to in the large group market. As such, large group
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policies regulated by CDI do not have the same basic
health care coverage requirements as plans regulated by
DMHC. Federal law mandating coverage of EHBs applies to
insurers regulated under the Insurance Code. In
addition, certain services are mandated under state law
for all plans and insurers.
iii) Non-contracting provider payments. Regulations
implementing the Knox-Keene Act specify the way disputed
claims, such as claims for payment for out-of network
services, will be calculated. For out-of-network
providers, the payments should be the "reasonable and
customary value" based on specified information, and
taking into account factors that provide guidance for
providers and plans as a way to help determine a
reasonable payment amount. The Insurance Code does not
provide criteria for non-contracting provider
reimbursement, except for providers whose contract with
an insurer has terminated resulting in them becoming an
out-of-network provider. Without such criteria, insureds
could be held financially liable if the insurers and
providers are not able to come to an agreement on the
amount owed for non-contracted services.
Other key consumer protection areas that have differences
between the Knox-Keene Act and the Insurance Code include
grievances and appeals processes, plan and policy
compliance surveys, and the scope of independent medical
reviews.
d) Managed Care Organization (MCO) tax. DMHC-regulated
plans pay the corporate income tax. Additionally, MCMC
plans, all of which are regulated by DMHC (with exception
of County Organized Health Systems (COHS) regulated by
DHCS), pay the MCO tax, which is a sales tax of 3.975% of
gross receipts. For 2015-16, the current MCO tax is
projected to generate $1.13 billion in non-federal funding
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for the Medi-Cal program. These funds are matched with
federal funds to provide the Medi-Cal program over $2
billion.
In July 2014, the Centers for Medicare and Medicaid
Services (CMS) issued guidance indicating that MCO tax
structures similar to California's were no longer
permissible for the purposes of funding the Medi-Cal
program, and required states with such taxes to make
certain modifications. Based on the July federal guidance
and federal regulations, any modified proposal for the MCO
tax would need to be generally broad-based and uniform, and
not contain hold harmless provisions. As a practical
matter, broad-based means that all plans, not just Medi-Cal
plans, must pay the tax. Another important federal
requirement is that although some of the plans paying the
tax will get their money and more in higher Medi-Cal rates,
there must be tax payers who lose, specifically plans that
pay more in tax than they get back in higher rates. This
federal requirement is in place so that states do not
design taxes where all providers get more money back than
they put in, once the match is included.
This year, two MCO tax proposals were introduced to
establish a new MCO tax that satisfies federal
requirements. The Governor's budget proposed to replace
the existing MCO tax with a broad-based MCO tax that
applies across all managed care plans regulated by DMHC and
a few COHS plans regulated by DHCS. The Administration
estimates that revenues from this tax will offset General
Fund (GF) spending for Medi-Cal by $800 million in 2014-15
and $1.1 billion in 2015-16. Additionally, the MCO tax
will be sufficient to raise the funding necessary to
eliminate a 7% reduction in in-home supportive services
(IHSS) hours.
The second MCO tax proposal is contained in ABX2 4
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(Levine), which proposes a flat MCO tax, also paid by all
MCOs regulated by DMHC and DHCS. The author of the flat
tax proposal states that it will raise $1.878 billion, with
$1.1 million to support Medi-Cal, as well as sufficient
funding to restore a 7% reduction in IHSS hours, a 10% rate
increase for service providers to the developmentally
disabled. If funds remain, they would be dedicated to
improving Medi-Cal provider rates. Recently, the
Administration has proposed another MCO tax which will
raise $1.35 billion. This option attempts to address the
criticisms of the Governor's earlier proposal.
All proposals would include PPOs regulated by DMHC as
taxpaying MCOs, estimate their revenues on enrollment of
DMHC and DHCS-regulated plans, and require a two-thirds
vote for passage.
e) GPTs. Insurance companies regulated by CDI are subject
to a GPT equal to 2.35% of all premiums written. This tax
is in lieu of all other taxes except property taxes and
vehicle license fees. Thus, insurers do not pay tax on
other forms of income, such as investment income or income
earned from other trades or businesses. According to the
Legislative Analyst's Office, the GPT appears, in most
years, to raise more revenue than would be raised by
applying the corporate taxes to insurers' net income.
Insurers under CDI cannot be subject to the MCO tax.
If a PPO is shifted from DMHC to CDI, as proposed by this
bill, that PPO would no longer pay corporate or MCO taxes.
Instead, it would pay GPTs. The author and sponsors assert
that $300 million in annual revenue would be generated for
the GF.
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The California Department of Finance (DOF) recently
released a preliminary fiscal analysis of AB 1434
(McCarty), virtually identical to this bill. The analysis
determined that if PPOs and EPOs were shifted to CDI
jurisdiction, there would be a net revenue gain of
approximately $240 million in GF ($300 million increase in
GPT, less $60 million in corporate taxes that would no
longer be paid). However, approximately $130 million of
this revenue would be subject to Proposition 98 minimum
guarantees (to fund education), and $3.6 million would be
subject to Proposition 2 "rainy day fund" obligations.
Thus, $106.4 million would be left as net GF revenue. DOF
estimates that the impact of this bill on the Governor's
earlier MCO tax proposal would result in decreased General
Fund revenue of $30 million resulting from fewer lives
under DMHC's jurisdiction.
The administration also asserts that this bill could be
interpreted in that it would apply to all commercial plans,
including HMOs, under DMHC's jurisdiction. Under this
scenario, DOF estimates a net revenue gain of $1.6 billion
in GF revenues, reduced down to $726 million after
Propositions 98 and 2 guarantees are applied. However, DOF
estimates that the impact under this scenario on the MCO
tax would be decreased GF revenue of approximately $1.35
billion, and because of the decreased number of lives under
DMHC's jurisdiction, the Administration's MCO tax proposal
would likely be infeasible. Neither the author nor
sponsors have expressed intent for this bill to apply to
any plans other than PPOs and EPOs.
f) Recent litigation. According to the Assembly Committee
on Revenue and Taxation, the issue of GPTs is currently the
subject of ongoing litigation pending before the California
Court of Appeal. Specifically, on July 3, 2013, Michael D.
Myers filed a taxpayer action alleging that the Insurance
Commissioner, the State Board of Equalization, and the
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State Controller have all failed to perform their duties
under California law to assess and collect GPT from Blue
Shield and Blue Cross. Blue Shield and Blue Cross, in
turn, filed demurrers asserting, among other things, that
neither entity is an "insurer" subject to GPT. The trial
court sustained the demurrers and noted that it was
undisputed that neither Blue Shield nor Blue Cross is
licensed by the Insurance Commissioner. Mr. Myers has
appealed the trial court judgment. Additionally, the
Insurance Commissioner argues that the Myers trial court
erred in mechanically concluding that because Blue Shield
and Blue Cross are denominated as plans under Knox-Keene,
and regulated by the DMHC, they are exempt from GPT. The
Insurance Commissioner contends that Blue Shield and Blue
Cross's DMHC-regulated products are subject to GPT, and
that legislative changes permitting Blue Shield and Blue
Cross to sell indemnity products under DMHC jurisdiction
did not change the character of those products from
"insurance" to something else.
3)SUPPORT. According to the California Insurance Commissioner
Dave Jones, the sponsor of this bill, existing law allows
Anthem Blue Cross and Blue Shield of California to choose the
regulator with which to file their PPO products. Supporters
state that these companies were granted special separate
exceptions that allowed them to sell regulated PPO business
under DMHC licenses, thereby creating an uneven playing field
among PPOs as they compete in the marketplace. The Insurance
Commissioner cites differences in the nature of HMO and PPO
products, stating that there would be substantial consumer
protection harms to PPO policyholders as a result of the move
to DMHC regulation; specifically, that those under DMHC
jurisdiction are subjected to lesser financial solvency
requirements and oversight. The Insurance Commissioner
asserts that Blue Shield had its 2014 products disapproved by
CDI for non-compliance with the ACA and non-compliance with
the network adequacy law; and, rather than amending those
filings in order to comply with the law, they instead filed
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the products with DMHC.
The Insurance Commissioner argues that Anthem is similarly
moving their PPO products to regulation under DMHC, and that
these special exceptions in law also prevent Anthem Blue Cross
and Blue Shield from paying their fair share of taxes;
specifically, companies that file their PPO policies with DMHC
pay corporate income tax on their net income instead of the
gross premium tax of 2.35% on all premiums received that all
insurers pay under the state's Constitution, resulting in the
GF forgoing more than $1 billion from 2004-2011. The
Insurance Commissioner states that California should eliminate
these special exceptions allowing these two companies to
regulator shop, and in doing so, they will pay their fair
share of taxes and generate approximately $300 million in
annual revenue that the Legislature could be used to improve
Medi-Cal provider reimbursement rates.
According to the California Medical Association and the
Congress of California Seniors, this bill will end regulator
shopping by closing a loophole with creates an uneven playing
field among PPOs, and will provide additional state revenue to
increase Medi-Cal provider reimbursement. The supporters
state that special exceptions for Anthem Blue Cross, and Blue
Shield of California prevent them from paying their fair share
of taxes. Rather than paying GPT, these companies pay
corporate income tax instead, resulting in a significant loss
to the GF. This loss will increase over time as premiums grow
and as more people enroll in insurance. Supporters state that
this bill will increase GF revenue by $300 million, making
additional funds available to increase Medi-Cal provider
rates, which are among the lowest in the nation.
4)OPPOSITION. Health Access California (HAC), Consumers Union,
and the Western Center on Law and Poverty oppose this bill
unless amended to provide at least the same level of consumer
protections that are provided under the Knox-Keene Act, and
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unless it produces more ongoing revenue dedicated to Medi-Cal
than the proposed MCO tax. The opponents state that, as
drafted, this bill provides no guarantee that any revenue
generated will be directed to the Medi-Cal program, and that,
by moving a significant share of covered lives from DMHC to
CDI, this bill reduces the base for the MCO tax, thus
resulting in fewer funds for the Medi-Cal program. The
organizations also cite several consumer protections in the
Knox-Keene Act that are not similarly in the Insurance Code,
including balance billing prohibition, a definition of basic
health services, routine medical surveys of plans, broader
grievance and appeals provisions, and others. They state that
without equal protections between the two departments,
consumers' plans should not be moved to CDI. HAC also adds,
traditionally insurers migrated away from DMHC to CDI, to take
advantage of the lesser benefit standards. More recently,
with the implementation of minimum benefit standards, there
has been a flow of insurers back to DMHC.
The California Association of Health Plans (CAHP) states, in
opposition, that DMHC currently regulates the vast majority of
the health insurance market, and enrollees in these
DMHC-licensed products are afforded substantial protections,
such as a ban on balance billing in most circumstances. CAHP
states that this bill would arbitrarily shift most of this
market from one regulator to another without a valid reason,
causing major disruption in the market place for consumers and
providers. CAHP states that California is at a critical
moment in health care reform, and that supporters of this
proposal have not explained how this fundamental change in
regulation will improve care or promote affordability.
The California Chamber of Commerce (CalChamber) states that
this bill seeks to increase taxes for two of the state's
largest health plans without requiring a two-thirds vote of
the Legislature, therefore violating the California
Constitution. CalChamber outlines various arguments as to why
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this bill constitutes a tax subject to a two-thirds vote
requirement, including that the payers subject to the bill
would pay taxes that would be conferred to the GF for general
purposes, rather than for a specific benefit or privilege
conferred upon the payer. CalChamber argues that even if the
Legislature agrees that moving PPOs to CDI jurisdiction is
good policy, to do so would result in a taxpayer paying a
higher tax, and as such, the California Constitution requires
that it be approved by a two-thirds vote of the Legislature.
5)RELATED LEGISLATION.
a) AB 1434 (McCarty) contains identical provisions as those
in this bill.
b) ABX2 4 requires health plans to pay MCO tax at a flat
tax rate of $7.88 per enrollee per month.
6)PREVIOUS LEGISLATION. SB 78 (Committee on Budget and Fiscal
Review), Chapter 33, Statutes of 2013, establishes the MCO tax
beginning July 1, 2013 through July 1, 2016.
7)POLICY COMMENTS.
a) Consumers will lose some protections if PPOs are shifted
to CDI. Despite ongoing efforts by the Legislature,
Administration, and Insurance Commissioner to bring parity
between the Knox-Keene Act and the Insurance Code, there
are still significant differences between the two when it
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comes to consumer protections. As a matter of public
policy, ensuring the strongest consumer protections is of
the utmost importance, particularly in light of current
individual coverage mandates under the ACA. It is
important to weigh the practical effects of this bill on
consumers, one of which is that PPO consumers would lose
access to key protections they currently benefit from as
enrollees of Knox-Keene licensed plans. It would be
prudent for more work to be done to bring complete parity
with the Knox-Keene Act with respect to consumer
protections before shifting millions of consumers to the
CDI.
b) This bill could result in less funding for Medi-Cal. By
moving all PPOs under the jurisdiction of CDI, this bill
would effectively reduce MCO tax revenues and likely result
in less funding for Medi-Cal. Under this bill, millions of
covered lives would be shifted to CDI jurisdiction and no
longer subject to the MCO tax. The author and sponsor
state that this bill would generate $300 million for the GF
by subjecting those lives to the GPT. However, once the
revenues go to the GF, they will be subject to Proposition
98 funding guarantees for education, as well as Proposition
2, which establishes the state's rainy day fund. Once
these obligations are met, while Medi-Cal could receive
some proportion of the remaining revenues after
Propositions 98 and 2 are applied, what is left of the
revenues could not be guaranteed for the Medi-Cal program.
While funding for Medi-Cal is a top priority of many when
it comes to health policy, Medi-Cal would have to compete
with a myriad of other interests to secure the additional
funding from the GF. This bill does not provide any
provisions or safeguards to assure that the funding would
be secured for the Medi-Cal program.
In contrast, the MCO tax generates a direct source of
funding for the Medi-Cal program. Further, the MCO tax
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provides the state with the opportunity to draw down
matching federal funds for Medi-Cal. For every MCO tax
dollar lost, there will be a matching federal dollar
forgone. The MCO tax expires June 30, 2016 and no new tax
has been authorized, although clearly there is a
significant amount of time before its expiration. However,
if a new MCO tax is not authorized then many of the
concerns of the opposition will be moot.
c) Bill creates uncertainty for a future MCO tax. A goal
of the second extraordinary session is to identify funding
sources to support the Medi-Cal program, and to identify an
MCO tax structure that meets federal requirements in order
to allow the tax to continue. The Administration's new
proposal imposes a specified tax on an MCO's enrollment.
By shifting millions of lives from DMHC jurisdiction to
CDI, this bill makes it more challenging to assess the
impact of a proposed MCO tax, adding uncertainty as to
whether or not a successor MCO tax will be achieved in the
special session.
d) This bill may not apply solely to Anthem Blue Cross and
Blue Shield of California. While the author and sponsors
highlight Anthem Blue Cross and Blue Shield of California
PPO products as the two main insurers subject to this bill,
the bill applies to all full-service PPO plan, specialized
PPO plans, and EPOs. As such, the bill would result in not
only Anthem Blue Cross and Blue Shield of California's 2.6
million lives being shifted to CDI, but also millions of
covered lives currently in DMHC-regulated specialized PPO
and EPO plans. For example, according to data provided by
DMHC, Delta Dental alone had over 3 million covered lives
in 2014, and Vision Service Plan had 11.9 million. While
specialized plans lives tend to overlap, as some
individuals have full-service, dental, and vision plans, or
some combination thereof, these numbers provide context to
the sheer numbers of consumers who may be impacted by this
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bill. The scope of this bill exacerbates the
aforementioned concerns over consumer protections, and to
some degree the MCO tax (specialized plans are not subject
to the MCO tax and it is unknown how many lives other
DMHC-regulated full-service PPO products will enroll in
2015 and beyond). Additionally, it also raises questions
as to the capacity of CDI to readily absorb the impact of
such a significant increase in the number of covered lives
under its jurisdiction.
REGISTERED SUPPORT / OPPOSITION:
Support
California Insurance Commissioner Dave Jones (sponsor)
California Medical Association
Congress of California Seniors
Opposition
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California Association of Health Plans
California Chamber of Commerce
Consumers Union (unless amended)
Health Access California (unless amended)
Western Center on Law and Poverty (unless amended)
Analysis Prepared by:Kelly Green / HEALTH / (916) 319-2097