BILL ANALYSIS                                                                                                                                                                                                    



                                                                  AB 1140
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          ASSEMBLY THIRD READING
          AB 1140 (Niello)
          As Amended April 14, 2009
          Majority vote

           BUSINESS & PROFESSIONS     11-0                                 
           
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          |Ayes:|Hayashi, Emmerson,        |     |                          |
          |     |Conway, Eng, Hernandez,   |     |                          |
          |     |Nava, Niello,             |     |                          |
          |     |John A. Perez, Price,     |     |                          |
          |     |Ruskin, Smyth             |     |                          |
          |-----+--------------------------+-----+--------------------------|
          |     |                          |     |                          |
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           SUMMARY  :  Revises the definition of "responsible third-party  
          payer" to include a person or entity who contracts with  
          insurance carriers, self-insured employers, third-party  
          administrators, or any other person or entity who, pursuant to a  
          contract, is responsible to pay for Computerized Tomography  
          (CT), Positron Emission Tomography (PET), or Magnetic Resonance  
          Imaging (MRI) diagnostic imaging services provided to a patient  
          covered by that contract.  

           FISCAL EFFECT  :   Unknown.  This bill is keyed non-fiscal.

           COMMENTS  :  According to the author's office, "The intent of AB  
          1140 is to clarify the definition of 'responsible third-party  
          payer' to ensure that legitimate contracting entities are not  
          prohibited from providing services to the Health and Workers'  
          Compensation insurance communities.  A vague definition of  
          'responsible third-party payer' was included in last year's AB  
          2794 (Blakeslee), Chapter 469, Statutes of 2008, which led some  
          to believe that AB 2794 actually barred contracting entities  
          from entering into contracts with their networks for their  
          diagnostic imaging needs."  

          AB 2794's primary purpose, as evidenced by the author's intent  
          statement, was to eliminate the practice of physicians  
          over-referring for imaging services due to financial incentives  
          created by lease arrangements with radiological vendors.  The  
          bill explicitly prohibited healthcare licensees from billing for  
          services that were not actually provided by the licensee.  The  








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          bill also required radiological facilities to directly bill  
          either the patient or a responsible third-party payer for  
          diagnostic imaging services rendered by those facilities.  The  
          bill defined "responsible third-party payer" as "any person or  
          entity who is responsible to pay for CT, PET, or MRI services  
          provided to a patient."  

          AB 2794 specifically exempted radiological facilities that  
          contract with health care service plans, and thus did not intend  
          for the "responsible third-party payer" to be traditional health  
          insurers.  The bill also exempted health care programs operated  
          by public entities, private educational institutions, and any  
          person or clinic that contracts with an employer to provide  
          diagnostic imaging services.  

          This bill's sponsors, the California Self-Insurers Association,  
          seeks to explicitly include in the definition of "responsible  
          third-party payer" a person or entity who contracts with  
          insurance carriers, self-insured employers, and third-party  
          administrators (TPAs) for the management and payment of  
          diagnostic imaging services.  This category of payer is not  
          specifically exempted under current law, and may not be covered  
          under the present definition of "third-party payer."     

          The sponsor's concern with current law is that although such  
          entities are responsible for paying for diagnostic imaging  
          services provided to a patient, in certain situations, they are  
          effectively "fourth-party payers."  This is because some  
          networks are effectively subcontracting from an employer's third  
          party-payer.  

          This bill would explicitly permit such entities (networks) to  
          continue their services under state law.  These networks  
          assemble diagnostic imaging facilities and contract their  
          services to insurance companies, self-insured employers, union  
          trusts, TPAs, business coalitions, and associations at a reduced  
          price.  The network pays the imaging facilities directly and  
          provides administrative functions related to scheduling and  
          logistical support services.  These entities do not cause a  
          referral to be made, but instead react to a physician's referral  
          for diagnostic imaging and direct the patient to a provider of  
          those services.  

          There are conflicting opinions at the state level regarding  








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          these contractual arrangements; a 2000 Attorney General  
          opinion determined that such network services were  
          effectively violating the prohibition against the corporate  
          practice of medicine, while a 2003 letter from the Medical  
          Board of California concluded the opposite, based on a 1991  
          counsel opinion from the Department of Consumer Affairs.  
           

          Analysis Prepared by  :    Sarah Huchel / B. & P. / (916) 319-3301  



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