BILL ANALYSIS Ó AB 1739 Page 1 Date of Hearing: April 27, 2016 ASSEMBLY COMMITTEE ON APPROPRIATIONS Lorena Gonzalez, Chair AB 1739 (Waldron) - As Amended April 19, 2016 ----------------------------------------------------------------- |Policy |Health |Vote:|18 - 0 | |Committee: | | | | | | | | | | | | | | |-------------+-------------------------------+-----+-------------| | | | | | | | | | | | | | | | ----------------------------------------------------------------- Urgency: No State Mandated Local Program: NoReimbursable: No SUMMARY: This bill requires the Department of Health Care Services (DHCS), in the evaluation of patients for allergy under fee-for-service (FFS) Medi-Cal, to treat serologic-specific immunoglobulin E (IgE) tests (blood tests) and skin tests as equivalent confirmatory tests. FISCAL EFFECT: AB 1739 Page 2 Uncertain, likely minor overall fiscal effect in the FFS Medi-Cal program (GF/federal). Blood testing utilization could go up, while utilization of skin tests could go down. The net effect is unknown. COMMENTS: 1)Purpose. This bill is intended to ensure that Medi-Cal patients with allergies receive timely diagnoses. Under current practice, if a primary care physician wishes to diagnose allergies, a referral to a specialist for skin testing is allowed. However, if the primary care physician wishes to order a blood test to diagnose allergies without a referral, the physician can only do so under certain circumstances. The author notes this bill will facilitate reimbursement for blood tests offered by primary care providers, which the author indicates will increase access to allergy diagnostic testing. 2)Background. Allergy and asthma are prevalent in the general population. In California, an estimated 2.5 million adults have asthma along with about 700,000 children. With respect to food allergies, a recent study estimates that food allergy affects 5% of children under the age of five years and 4% of teens and adults, and its prevalence appears to be on the increase. AB 1739 Page 3 DHCS and other payers often translate guidelines into medical coverage specifications. Medi-Cal coverage for allergy testing aligns with 2008 guidelines issued by the American Academy of Allergy, Asthma & Immunology (AAAAI). Guidelines by other organizations, such as the National Institutes of Health, also address the effectiveness of allergy diagnostic tests. The AAAAI guidelines upon which Medi-Cal's coverage policy are based are being updated this year. Proponents of this bill note the 2008 guidelines are out of date, and also note practical considerations that Medi-Cal patients face obtaining allergy skin testing, which requires an appointment with an allergist. Unlike skin tests, blood tests can be administered in a primary care setting. This issue was the subject of an August 12, 2014 Assembly Health Committee informational hearing, which focused broadly on the potential for utilization controls to interfere with providing access to the standard of care, as well as specifically on reimbursement for allergy diagnostic testing. Subsequent to the hearing, on May 15, 2015, Medi-Cal removed the requirement that laboratories submit documentation of medical necessity with claims for blood test reimbursement. However, other limitations on Medi-Cal coverage for blood tests remain. It should be noted, however, that diagnostic tests are not a slam dunk for diagnosing allergies. A 2012 article in the journal Pediatrics providing guidelines to pediatricians discusses the complexity of allergy diagnosis, and notes a detection of sensitization to an allergen through a blood test is not equivalent to a clinical diagnosis. Many children with positive tests have no clinical illness when exposed to the allergen. They indicate this limitation highlights the need for the clinician to use a detailed medical history and have knowledge of the features of the specific illness when AB 1739 Page 4 selecting and interpreting tests. In essence, these tests require a level of training in how to interpret them in light of other relevant patient-level considerations outside of the blood test results. Because test limitations often warrant additional evaluation to confirm the role of specific allergens, the article advises a consultation with a board-certified allergist-immunologist should be considered. 3)Staff Comments. Evidence-based coverage guidelines generally ensure care is provided in a manner supported by science and medical consensus. These guidelines are constantly evolving as new research is published and reviewed. This bill, as written, would statutorily dictate specific coverage parameters for certain tests, which is not common practice, and has the disadvantage of being static and less flexible to changing guidelines as well as lacking review by medical professionals. Staff also notes the clinical guidelines upon which Medi-Cal coverage is based are already in the process of being updated, raising questions of whether this bill is premature. On the other hand, if difficulty and hassle accessing allergists and receiving skin tests delay or prevent diagnosis of allergy where it would be helpful, there seems to be merit to considering the real-world impact of coverage guideline on access to timely and appropriate care in a real-world setting. Analysis Prepared by:Lisa Murawski / APPR. / (916) 319-2081 AB 1739 Page 5