BILL ANALYSIS                                                                                                                                                                                                    



                                                                       



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          |SENATE RULES COMMITTEE            |                   AB 952|
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                                 THIRD READING


          Bill No:  AB 952
          Author:   Krekorian (D)
          Amended:  7/23/09 in Senate
          Vote:     21

           
           SENATE HEALTH COMMITTEE  :  11-0, 7/8/09
          AYES:  Alquist, Strickland, Aanestad, Cedillo, Cox,  
            DeSaulnier, Leno, Maldonado, Negrete McLeod, Pavley, Wolk

           SENATE JUDICIARY COMMITTEE  :  5-0, 7/14/09
          AYES:  Corbett, Harman, Florez, Leno, Walters

           SENATE APPROPRIATIONS COMMITTEE  :  Senate Rule 28.8

           ASSEMBLY FLOOR  :  76-0, 6/2/09 - See last page for vote


           SUBJECT :    Health information:  disclosure:  Taft-Hartley  
          plans

           SOURCE  :     Pacific Federal Benefit Administrators 


           DIGEST :    This bill permits a health care provider, health  
          care service plan, or contractor to disclose medical  
          information to an employee welfare benefit plan formed  
          under the federal Taft-Hartley Act if the disclosure meets  
          specified conditions, including that it is for the purpose  
          of determining eligibility, coordinating benefits, or to  
          allow the employee welfare benefit plan to advocate on  
          behalf of the patient or enrollee, as specified.  The  
          request for information must be accompanied by a written  
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          authorization for release of the information from the  
          patient or other authorized person, and the disclosure must  
          be permitted by and made in a manner consistent with the  
          Health Insurance Portability and Accountability Act of 1996  
          (HIPAA).  This bill also permits the disclosure of medical  
          information to an entity contracting with the employee  
          welfare benefit plan for services, as specified. 

           ANALYSIS  :    Existing law, the Confidentiality of Medical  
          Information Act (CMIA), prohibits a health care provider,  
          health care service plan, or contractor from disclosing  
          medical information regarding a patient, enrollee, or  
          subscriber without first obtaining an authorization, except  
          as specified.  (Civ. Code Sec. 56.10(a).)  

          Existing law requires a provider of health care, health  
          care service plan, or contractor to disclose medical  
          information if the disclosure is compelled as specified  
          (Civ. Code Sec. 56.10(b)) and permits a provider of health  
          care or service plan to disclose medical information in  
          specified circumstances.  (Civ. Code Sec. 56.10(c).)

          Existing law prohibits a health insurer or health care  
          service plan from releasing any information that would  
          indicate to an employer that an employee is receiving or  
          has received services from a health care provider covered  
          by the plan, unless the employee authorizes the disclosure.  
           (Ins. Code Sec. 791.27, Health & Saf. Code Sec. 1374.8.)

          Existing federal law prohibits, under HIPAA, covered  
          entities from using or disclosing protected health  
          information, except as specified.  Existing federal law  
          defines "covered entities" to include health plans, health  
          care clearinghouses, and health care providers that  
          transmit any health information in electronic form.   
          Federal law also defines "health plan" to include a group  
          health plan, an employee welfare benefit plan, or any other  
          arrangement that is established or maintained for the  
          purpose of offering or providing health benefits, as  
          specified.  (42 U.S.C. 1320d et seq., 45 C.F.R. 164.500 et  
          seq.)   

          This bill amends CMIA to permit a health care provider or a  
          health plan to disclose medical information to:  (1) an  







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          employee welfare benefit plan, as defined under the federal  
          Employee Retirement Income Security Act of 1974 (ERISA),  
          which is formed under the federal Taft-Hartley Act, to the  
          extent the benefit plan provides medical care; and (2) an  
          entity contracting with the plan for billing, claims  
          management, medical data processing, or other  
          administrative services related to the provision of medical  
          care to persons enrolled in the plan for health care  
          coverage.  In both cases, all of the following conditions  
          must be met:

          1.The disclosure is for the purpose of determining  
            eligibility, coordinating of benefits, or allowing the  
            employee welfare benefit plan, or the contracting entity,  
            to advocate on behalf of a patient or enrollee with a  
            health care provider, a health care service plan, or a  
            state or federal regulatory agency.

          2.The request for the information is accompanied by a  
            written authorization for the release of the information  
            as provided under CMIA which requires that the  
            authorization be submitted by the patient, the legal  
            representative of the patient (if the patient is a minor  
            or an incompetent), the spouse of the patient or the  
            person financially responsible for the patient under  
            specified circumstances, or the beneficiary or personal  
            representative of a deceased patient.

          3.The disclosure is authorized by and made in a manner  
            consistent with HIPAA; and 

          4.Any information disclosed is not further used or  
            disclosed by the recipient in any way that would directly  
            or indirectly violate CMIA or the restrictions imposed by  
            federal HIPAA regulations, including the manipulation of  
            the information in any way that might reveal individually  
            identifiable medical information.  

          This bill specifies that Health and Safety Code Section  
          1374.8 would not apply to the bill's provisions.  That  
          section prohibits a health care service plan from releasing  
          any information to an employer that would indicate to the  
          employer that an employee is receiving or has received  
          services from a health care provider covered by the plan  







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          unless the employee authorizes the disclosure. 

           FISCAL EFFECT  :    Appropriation:  No   Fiscal Com.:  Yes    
          Local:  Yes

           SUPPORT  :   (Verified  8/19/09)

          Pacific Federal Benefit Administrators (source) 
          Building Material, Construction, Industrial, Professional  
          and Technical
          California Association of Joint Powers Authorities
          California Conference of Machinists
          California Teamsters Public Affairs Council
          International Alliance of Theatrical Stage Employees Local  
          80
          International Longshore and Warehouse Union
          International Union of Security, Police and Fire  
          Professionals of America  and Participating Employers  
          Health & Welfare Fund 
          Legal Aid Foundation of Los Angeles County's
          Liberty Dental Plan
          Neighborhood Legal Services
          Professional Musicians Local 47 Employers' Health and  
          Welfare Fund
          Teamsters Local 36
          Teamsters Local 572
          Trustees of the Public Employees Benefit Trust 
          Trustees of the South Bay Teamsters and Employers Health  
          and Welfare and Related Benefits Trust 
          Trustees to the Union Heritage Trust
          United Food & Commercial Workers Western States Council
          UNITE-HERE!
          Valley Industry and Commerce Association 
          Western Alliance Trust Fund


           ARGUMENTS IN SUPPORT  :    According to the author's office:

               In recently adopted federal regulations around HIPAA,  
               a problem has emerged with provisions that give  
               deference in the implementation of HIPAA to more  
               strict state law.  As a result, a uniquely structured  
               class of health plans present in California (ERISA  
               Taft-Hartley Trusts regulated by the federal  







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               Department of Labor), is unduly burdened by a quirk in  
               state law.  

               Both HIPAA and CMIA allow appropriate Protected  
               Information to be shared with appropriate health plan  
               administrators in order to facilitate efficient and  
               proper administration of health benefits for  
               patients/consumers.  If Protected Information is not  
               allowed to be shared with the Taft-Hartley Plan,  
               consistent with HIPAA and CMIA, the plan will not know  
               whether it is paying health care providers for the  
               appropriate benefits, for the right patients/consumers  
               and at the appropriate level of compensation.

               The unfortunate quirk in California Law is that CMIA  
               does not recognize an ERISA DOL Taft-Hartley Health  
               Plan as a "Health" plan, and therefore health care  
               providers, in the absence of state law regarding  
               Taft-Hartley Plans, are imposing requirements for  
               sharing Protected Information that are even more  
               stringent than state law.


           ASSEMBLY FLOOR  : 
          AYES:  Adams, Ammiano, Anderson, Arambula, Beall, Tom  
            Berryhill, Blakeslee, Blumenfield, Brownley, Buchanan,  
            Caballero, Charles Calderon, Carter, Chesbro, Conway,  
            Cook, Coto, Davis, De La Torre, De Leon, DeVore, Duvall,  
            Emmerson, Eng, Evans, Feuer, Fletcher, Fong, Fuentes,  
            Fuller, Furutani, Gaines, Galgiani, Garrick, Gilmore,  
            Hagman, Harkey, Hayashi, Hernandez, Hill, Huber, Huffman,  
            Jeffries, Jones, Knight, Krekorian, Lieu, Logue, Bonnie  
            Lowenthal, Ma, Mendoza, Miller, Monning, Nava, Nestande,  
            Niello, Nielsen, John A. Perez, V. Manuel Perez,  
            Portantino, Price, Ruskin, Salas, Saldana, Silva,  
            Skinner, Smyth, Solorio, Audra Strickland, Swanson,  
            Torlakson, Torres, Torrico, Tran, Villines, Yamada
          NO VOTE RECORDED:  Bill Berryhill, Block, Hall, Bass


          RJG:nl  8/19/09   Senate Floor Analyses 

                         SUPPORT/OPPOSITION:  SEE ABOVE








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