BILL ANALYSIS                                                                                                                                                                                                    






                                 SENATE HEALTH
                               COMMITTEE ANALYSIS
                        Senator Elaine K. Alquist, Chair


          BILL NO:       AB 1543                                      
          A
          AUTHOR:        Jones and Fletcher                           
          B
          AMENDED:       June 11, 2009
          HEARING DATE:  June 17, 2009                                
          1
          CONSULTANT:                                                 
          5
          Park/                                                       
          4
                                                                       
                                         3
                                        
                                     SUBJECT
                                         
                          Medicare supplement coverage

                                     SUMMARY  

          Makes conforming changes to the requirements and standards  
          that apply to Medicare supplement contracts and policies  
          (collectively Medigap policies), for the purpose of  
          complying with recent federal law changes affecting the  
          benefits, the issuance, and the pricing of Medigap  
          policies.  

                             CHANGES TO EXISTING LAW  
          
          Existing federal law:
          Existing federal law establishes the Medicare program as a  
          government-administered health insurance program for people  
          age 65 or older and certain people younger than age 65,  
          such as those with disabilities and those who have  
          permanent kidney failure.

          Existing federal law, under the Medicare Improvements for  
          Patients and Providers Act of 2008 (MIPPA), requires states  
          to adopt by September 24, 2009, specific modernization  
          changes to Medigap policies, as outlined in the model  
          regulations developed by the National Association of  
                                                         Continued---



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          Insurance Commissioners (NAIC), and consistent with  
          requirements in MIPPA.  MIPPA reduces from 14 to 11 the  
          number of standardized Medigap policies, and makes other  
          changes to Medigap coverage including changes to benefit  
          and cost-sharing requirements, and changes to disclosure  
          and issuance requirements.

          Existing federal law, under the Genetic Information  
          Nondiscrimination Act of 2008 (GINA), prohibits a health  
          insurer, including issuers of Medigap policies, from  
          denying or conditioning the issuance, effectiveness, or  
          pricing of the policy on the basis of genetic information,  
          and requires states to enact conforming changes to Medigap  
          policies by July 1, 2009. 
          


          Existing state law:
          Existing state law provides for regulation of health plans  
          by the Department of Managed Health Care (DMHC) under  
          Knox-Keene and for regulation of health insurers by the  
          California Department of Insurance (CDI) under the  
          Insurance Code.

          Existing state law establishes standards for Medigap  
          policies sold in California, which provide Medicare  
          beneficiaries with coverage for benefits and cost-sharing  
          not covered by Medicare. Medigap policies are subject to  
          the jurisdiction of either DMHC or CDI depending on the  
          type of policy, in a manner generally consistent with  
          federal laws applicable to Medigap policies, including  
          benefit and cost-sharing requirements for 14 standardized  
          benefit plans, open enrollment and guaranteed issue of  
          Medigap policies for specified individuals, and specified  
          notices and disclosures that must be provided to Medigap  
          policy applicants and enrollees. 

          This bill:
          This bill would make conforming changes in state law  
          regarding standards applicable to Medigap policies to  
          comply with the federal MIPPA and GINA. 

           Changes related to MIPPA
           The bill would establish requirements for 11 new  
          standardized Medigap policies with an effective date on or  




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          after June 1, 2010, consistent with MIPPA, as follows:

           Reduce from 14 to 11 the number of standardized policies,  
            by eliminating Plans E, H, I, J and High-Deductible Plan  
            J as the existing standardized policies, and establishing  
            the 11 new standardized policies as Plans A-D, Plan F,  
            High-Deductible Plan F, Plan G, and Plans K-N;

           Require health plan and health insurer issuers of Medigap  
            policies (issuers) to, at a minimum, offer the basic  
            plan, Plan A, and require issuers choosing to offer any  
            Medigap policy or policies other than Plan A to also  
            offer either Plan C or Plan F; 

           Delete from the new standardized Medigap policies  
            preventive and at-home care benefits, and delete  
            prescription drug coverage from all standardized plans  
            (prescription drug coverage is now provided through  
            Medicare Part D);

           Include hospice and respite care services as basic (core)  
            benefits which must be included in all standardized  
            Medigap policies; 

           Make changes to cost-sharing elements of standardized  
            plans, as specified;


          The bill would retain and revise the existing standards  
          applicable to Medigap policies with an effective date on or  
          before June 1, 2010, with the following new provisions:

           Permitting issuers to allow an enrollee, subscriber,  
            policyholder, or certificate holder (enrollee) to  
            exchange an existing policy for one of the new  
            standardized policies, and requiring issuers that choose  
            to do so to comply with specified requirements,  
            including, among other things, limiting any new  
            preexisting condition exclusion to six months, as  
            specified, and only for benefits not covered in the prior  
            policy; and,

           Requiring an issuer choosing to offer an enrollee the  
            opportunity to change to a newer policy to make the same  
            offer to all enrollees in a particular policy, unless to  




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            do so would be in violation of state or federal law.

          The bill would establish, for the purposes of open  
          enrollment, a correlation between 1990 standardized  
          Medicare supplement benefit plan letters (A, B, C, D, E, F,  
          high deductible F, G, H, I, J, high deductible J, K, and L)  
          and 2010 standardized Medicare supplement benefit plan  
          letters (A, B, C, D, F, high deductible F, G, K, L, M, N),  
          in the determination of what constitutes "equal" benefits.  
          (Existing law allows individuals to be entitled to an  
          annual open enrollment period lasting 30 days or more,  
          commencing with the individual's birthday, during which  
          time that person may purchase any Medicare supplement  
          coverage that offers benefits equal to or lesser than those  
          provided by the previous coverage.)

          The bill would clarify that an individual enrolled in  
          Medicare B is entitled to open enrollment, upon being  
          notified that he or she is no longer eligible for Medi-Cal  
          benefits, including benefits with a share of cost.  
          (Existing law establishes a right of open enrollment for  
          Medicare B enrollees who lose Medi-Cal coverage, but does  
          not specify whether losing benefits with a share of cost  
          qualifies the Medicare beneficiary to open enrollment.  
          Medi-Cal beneficiaries who have a change in their income  
          have a share of cost imposed.)
           
           The bill would require, upon timely receipt of notice from  
          an enrollee of their eligibility for Medi-Cal, as  
          specified, an issuer to refund any portion of the premium,  
          adjusted for paid claims, for that period during which an  
          enrollee is eligible for Medi-Cal and, at the enrollee's  
          request, the Medigap policy was placed in suspension.
           
           The bill would prohibit issuers from requiring, requesting  
          or obtaining health information, as part of the application  
          process, for an applicant who is eligible for guaranteed  
          issue or open enrollment for any Medicare supplement  
          coverage, except as specified. 

          The bill would clarify that beneficiaries are entitled to  
          guaranteed issue of a Medigap policy when the employer  
          ceases or terminates an employee welfare benefit plan that  
          provides Medicare supplemental benefits and no longer  
          provides insurance that covers all of the coinsurance  




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          charges under Part B of Medicare.  (Existing law requires  
          guaranteed issue of a Medigap policy for beneficiaries when  
          the employer ceases to provide coverage for some or all of  
          the supplemental benefits, but does not specifically  
          include a drop in coverage for Part B costs even where the  
          employer continues other Medigap coverage.)

          The bill would make conforming changes to marketing and  
          consumer notice provisions to reflect the changes in  
          standardized Medigap policies;

           Changes related to Genetic Information Nondiscrimination  
          Act of 2008
           For Medigap policies that become effective on or after May  
          21, 2009, the bill would require issuers, including a third  
          party administrator acting on behalf of an issuer, to  
          adhere to requirements of the federal Genetic Information  
          Nondiscrimination Act of 2008 (GINA), including, among  
          other things:

           Prohibiting an issuer from denying or conditioning the  
            issuance or effectiveness of a Medigap policy, including  
            any preexisting condition exclusion, or discriminating in  
            the pricing of a Medigap policy, on the basis of genetic  
            information with respect to an individual or family  
            member;

           Prohibiting an issuer from requesting or requiring an  
            individual or a family member of that individual to  
            undergo a genetic test, except for specified limited  
            exceptions, subject to specified rules and procedures; 

           Prohibiting an issuer from requesting, requiring,  
            seeking, or purchasing genetic information for  
            underwriting purposes; or with respect to any individual  
            or family member of the individual prior to the  
            individual's enrollment under the contract, in connection  
            with that enrollment;

           Enacting in state Medicare supplement law relevant  
            definitions from the federal GINA, including the  
            definition of "genetic information," which means, with  
            respect to any individual, information about the  
            individual's genetic tests, the genetic tests of family  
            members of the individual, and the manifestation of a  




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            disease or disorder in a family member of the individual;  
            and,

           Providing that Medicare supplement policies must also  
            comply with existing state law applicable to genetic  
            testing and genetic information.


          The bill makes other technical and conforming changes. As  
          an urgency measure, the bill's provisions would go into  
          immediate effect upon enactment.

                                         
                                 FISCAL IMPACT 

          According to the Assembly Appropriations Committee, the  
          bill would result in no direct fiscal impact to DMHC or CDI  
          to continue oversight of Medigap insurance policies and  
          enforce conformity with recent changes to federal law. 


                            BACKGROUND AND DISCUSSION  

          Author's statement
          The authors state that this bill conforms California law  
          related to Medigap policies to requirements in two new  
          federal laws: GINA and MIPPA.  The authors state that MIPPA  
          requires states to conform state Medigap law to changes  
          made by the NAIC model Medigap regulation as a result of  
          the two new federal laws, and failure to enact the changes  
          in the NAIC model act by the specified deadlines will  
          result in California losing its ability to regulate Medigap  
          policies.

          Medicare and Medigap policies
          Medicare is the federal health insurance program that  
          provides payment for certain medical expenses for most  
          people age 65 and older; certain disabled people under age  
          65, and people of all ages with end-stage renal disease  
          (permanent kidney failure treated with dialysis or a  
          transplant).  Medicare is the nation's largest health  
          insurance program and covers nearly 40 million Americans.

          Medicare has three types of benefits: 





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           Part A: The "hospital insurance program" covers inpatient  
            care in hospitals, skilled nursing facilities after a  
            hospital stay, and Religious Nonmedical Health Care  
            Institutions.  Part A also helps cover hospice services  
            and home health care services.  Most people are  
            automatically enrolled in Part A with no premium.  The  
            deductible for Part A (which is calculated for each  
            "benefit period," which is defined as the period  
            beginning on the first day of hospitalization and  
            extending until the beneficiary has not been an inpatient  
            of a hospital or skilled nursing facility for 60  
            consecutive days) is more than $1,000 for calendar years  
            2008 and 2009.

           Part B: The "supplementary medical insurance program"  
            covers a wide range of medical services, including  
            physicians' services and outpatient hospital services, as  
            well as equipment and supplies, such as prosthetic  
            devices. Part B is optional and most people will pay the  
            standard monthly Part B premium ($96.40 for 2008), but  
            some people will pay a higher premium based on their  
            income. The deductible for Part B in calendar years 2008  
            and 2009 is $135. Coinsurance for Part B is generally 20  
            percent of the Medicare-approved amount for the service,  
            but the beneficiary may also be subject to "excess  
            charges," or charges above the Medicare rate from  
            physicians or suppliers who don't accept the Medicare  
            rate. 

           Part D: The "voluntary prescription drug benefit program"  
            covers outpatient prescription drugs not otherwise  
            covered by Part B. 

          Beneficiaries can get their Part A and B benefits in two  
          ways. Under ''Original Medicare,'' beneficiaries get their  
          Part A and Part B benefits directly from the federal  
          government. Beneficiaries can also choose to get their Part  
          A and B benefits through private health plans, such as  
          HMOs, that contract with Medicare, which come under Part C  
          of Medicare, called the Medicare Advantage Program. 

          While Medicare provides extensive benefits, it is not  
          designed to cover the total cost of medical care for  
          Medicare beneficiaries. Under Original Medicare, even if  
          the items or services are covered by Medicare,  




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          beneficiaries are responsible for various deductible,  
          coinsurance, and in some cases copayment amounts. The  
          percentage of out-of-pocket health care expenses for  
          Medicare beneficiaries can be sizable and typically  
          increases with age.  In addition, there are medical  
          expenses that are not covered by Medicare at all, such as  
          custodial nursing home care, hearing aids; eyeglasses;  
          dental care; acupuncture; chiropractic care; and health  
          care outside the United States. 

          For these reasons, most people who do not have coverage  
          from a current or previous employer that covers these gaps  
          choose to get some type of additional coverage to pay some  
          of the costs not covered by Original Medicare. A Medicare  
          supplemental (Medigap) policy is a health insurance policy  
          sold by private insurance companies specifically to fill  
          "gaps" in Original Medicare coverage. A Medigap policy  
          typically provides coverage for some or all of the  
          deductible and coinsurance amounts applicable to  
          Medicare-covered services, and sometimes covers items and  
          services that are not covered by Medicare. Under federal  
          law, insurance companies can only sell standardized Medigap  
          policies, of which there are currently 11 (assigned letters  
          A thru N, with some letter plans eliminated such as the  
          current Plan E, H, I, and J, and two versions of plan F,  
          one of which is a high-deductible option).  In addition to  
          the core benefits which must be offered in all Medigap  
          policies, some plans may also cover other health care costs  
          that Medicare doesn't cover, such as foreign travel  
          emergency medical care.  

          Medigap policies are guaranteed issue at certain times for  
          eligible beneficiaries as specified in state and federal  
          law.  For example, at the point where an individual first  
          becomes eligible for Medicare there is an "open enrollment"  
          period where they can purchase any Medigap policy without  
          medical underwriting.  Beneficiaries are also guaranteed  
          coverage, or "guaranteed issue," when certain events occur,  
          such as the loss of employer-sponsored Medigap coverage.   
          Unless eligible for open enrollment or guaranteed issue,  
          Medicare beneficiaries wishing to purchase Medigap coverage  
          or change plans are subject to medical underwriting and can  
          be denied coverage based on their health status or claims  
          experience.  Medigap policies are guaranteed renewable as  
          long as the premium is paid and, generally speaking, cannot  




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          be cancelled because of a person's health condition or for  
          any reason other than non-payment of the premium.  Insurers  
          can however, in their discretion, increase the premiums for  
          Medigap coverage.

          NAIC and Medigap model regulation
          NAIC is the organization of insurance regulators from the  
          50 states, the District of Columbia and the five U.S.  
          territories.  NAIC meetings are a national forum for  
          resolving major insurance issues that allows regulators to  
          develop common national policies on the regulation of  
          insurance when a national policy is appropriate.  NAIC  
          develops and publishes model laws and regulations across  
          the broad spectrum of insurance issues, including health  
          insurance.  In order to be considered for development and  
          adoption, a NAIC model law or regulation must involve a  
          national standard and/or require uniformity among all the  
          states.  NAIC model laws often form the basis of state and  
          federal legislation and, in some instances, federal law  
          requires states to enact or to incorporate elements of NAIC  
          model laws. 

          The conference report of the Medicare Prescription Drug,  
          Improvement, and Modernization Act of 2003 (MMA) included  
          language encouraging the NAIC to adopt standards  
          modernizing the Medigap market.  In March 2007, NAIC  
          adopted a modernization proposal, and MIPPA, enacted on  
          July 15, 2008, provided for the implementation of these  
          changes and required states to adopt the NAIC changes.  On  
          September 24, 2008, the NAIC adopted the revised model  
          Medigap regulation, which includes major changes to Medigap  
          plans and benefits pursuant to MIPAA and also contains  
          changes required by GINA.  Under federal law, states must  
          adopt the NAIC model revisions in order to continue to  
          regulate the Medigap market; otherwise regulation of  
          Medigap policies falls to the federal Centers for Medicare  
          and Medicaid Services.  States must adopt the revisions  
          required by GINA by July 1, 2009 and the revisions required  
          by MIPPA by September 24, 2009.  

          California law incorporates, but is not identical to, the  
          federal law affecting Medigap policies. According the  
          Federal Register, in their notice of recognition of NAIC  
          Model Standards for Regulation of Medicare Supplemental  
          Insurance, while states generally cannot modify the  




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          standardized benefit packages set out in the NAIC Model,  
          with respect to other provisions, states retain the  
          authority to enact regulatory provisions that are more  
          stringent than those that are incorporated in the NAIC  
          Model Standards or in the statutory
          requirements.

          Medicare Improvements for Patients and Providers Act  
          (MIPPA)
          MIPPA, Public Law 110-275, includes major changes to  
          Medigap plans and benefits.  MIPPA reduces from 14 to 11  
          the number of standardized Medigap plans.  MIPPA requires  
          all issuers selling Medigap policies to offer at least the  
          basic standardized plan, Plan A, and requires issuers who  
          offer any other plan besides Plan A, to also then offer one  
          of two other plans, Plan C or Plan F.   MIPPA eliminates  
          certain Medigap benefits that were determined to be  
          underutilized or outdated, specifically the preventive care  
          benefit and the at-home recovery benefit, and removes  
          prescription drugs from some benefit plans as a result of  
          the establishment of Medicare Part D coverage for  
          prescription drugs under MMA.  According to the NAIC, the  
          eliminated preventive care benefit is no longer needed  
          because of the enhanced preventive care benefits now  
          offered in Medicare Part B.  NAIC reports the at-home  
          recovery benefit was an underutilized and outdated benefit  
          given the limited availability of the benefit in the old  
          plans, and no longer provided a significant benefit.  MIPPA  
          also adds hospice as a basic core benefit in all Medigap  
          policies.  

          Beneficiaries are not required to change to the new benefit  
          plans, which will be effective starting June 1, 2010.  In  
          addition, the NAIC model provides for transition to the new  
          standardized policies, but does not require issuers to  
          offer existing policyholders a chance to exchange their  
          current policy without medical underwriting, unless an open  
          enrollment or guaranteed issue situation is involved.  Once  
          the states adopt the revised model and issuers comply with  
          applicable state laws on approval of policy forms, rates  
          and advertising, issuers can market the new policies, but  
          they cannot become effective until June 1, 2010.

          Genetic Information Nondiscrimination Act (GINA)
          GINA, Public Law 110-233, enacted May 21, 2008, prohibits  




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          discrimination in health care coverage and employment based  
          on genetic information. GINA prohibits health insurers in  
          the group, individual, and Medigap policy markets from  
          denying coverage to a healthy individual or charging that  
          person higher premiums based solely on a genetic  
          predisposition to developing a disease in the future.  GINA  
          also bars employers from using individuals' genetic  
          information when making hiring, firing, job placement, or  
          promotion decisions.  In addition, insurers and employers  
          are not allowed under the law to request or demand a  
          genetic test, except for research-related purposes, and  
          only where the issuer adheres to specified disclosures and  
          limitations on the collection and use of the information.  
                                         
          A 2001 study by the American Management Association showed  
          that nearly two-thirds of major U.S. companies required  
          medical examinations of new hires.  In addition, 14 percent  
          conducted tests for susceptibility to workplace hazards; 3  
          percent for breast and colon cancer; 1 percent for sickle  
          cell anemia; and, 20 percent for family medical history. 

          Prior legislation
          SB 375 (Speier), Chapter 206, Statutes of 2005, made  
          certain changes to California's Medicare Supplement  
          coverage provisions to conform with the federal Medicare  
          Prescription Drug, Improvement, and Modernization Act of  
          2003. Expanded, as of January 1, 2007, eligibility  
          requirements for Medicare Supplement coverage including the  
          expansion of open enrollment to certain individuals who  
          lose Medi-Cal eligibility, and to individuals in Medicare  
          Advantage plans whose benefits are reduced. Prohibits  
          policy issuers from requesting health information from an  
          applicant who is guaranteed issuance of coverage. 
          
          Arguments in support
          CDI, sponsor of this bill, states that this bill is  
          urgently needed because if California fails to adopt the  
          revisions by the mandated deadlines, the state will be  
          deemed to be out of compliance with federal law, and  
          thereby, lose the authority to regulate the Medigap market.  
           America's Health Insurance Plans, the national association  
          representing health insurance plans, writes in support of  
          this bill that the timeliness with which these conforming  
          provisions must take effect and consistency with the NAIC  
          model regulation are essential to ensuring that Medicare  




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          supplement policies are available to millions of California  
          seniors. 


                                  PRIOR ACTIONS

           Assembly Floor:     74-0
          Assembly Appropriations:17-0
          Assembly Health:         19-0 
                                         
                                    COMMENTS

              1.   Urgency clause and conformity deadline. This bill  
               contains an urgency clause, which requires a  
               two-thirds vote of the Legislature, to ensure that the  
               provisions of this bill go into immediate effect upon  
               enactment. The deadline for states to comply with GINA  
               is July 1, 2009, and MIPPA is September 24, 2009. In  
               order to retain regulatory authority over the Medigap  
               market in California, California law must be amended  
               to comply with the federal requirements by the  
               deadlines. If states fail to adopt the revisions by  
               the mandated deadlines, then the state will be deemed  
               to be out of compliance with the federal requirements  
               and, thereby, lose the authority to regulate the  
               Medigap market in the state, and regulation of this  
               market would be assumed by the federal Centers for  
               Medicare and Medicaid Services (CMS).  

             2.   Recommended technical amendments. Staff recommends  
               that the authors consider incorporating the following  
               technical amendments into the final version of this  
               bill; however, due to the urgent nature of this  
               legislation, if consensus is not reached on all of the  
               following technical amendments in time to have the  
               measure go into effect on July 1, 2009, these  
               amendments should become part of a technical clean-up  
               bill at a later date.
           
           
           
           

                a. Page 13, lines 17-25:
                (C) An issuer may not apply new preexisting condition  




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               limitations or a new incontestability period to the  
               new plan contract for those benefits contained in the  
               exchanged 1990 standardized plan contract of the  
               enrollee or subscriber, but may apply preexisting  
               condition limitations of no more than six months to  
               any added benefits contained in the new 2010  
               standardized plan contract not contained in the  
               exchanged plan contract. This  subdivision  paragraph  
               shall not apply to an applicant who is guaranteed  
               issue under Section 1358.11 or 1358.12.

                b. Page 74, lines 5-13:  
                (C) An issuer shall not apply new preexisting  
               condition limitations or a new incontestability period  
               to the new policy for those benefits contained in the  
               exchanged 1990 standardized policy or certificate of  
               the insured, but may apply preexisting condition  
               limitations of no more than six months to any added  
               benefits contained in the new 2010 standardized policy  
               or certificate not contained in the exchanged policy.  
               This  subdivision  paragraph shall not apply to an  
               applicant who is guaranteed issue under Section  
               10192.11 or 10192.12.

                c. Page 22, lines 1-5:
                (C) If the Medicare supplement contract is terminated  
               by the  master policyholder  group contractholder and is  
               not replaced as provided under subparagraph (E), the  
               issuer shall offer enrollees or subscribers an  
               individual Medicare supplement contract which, at the  
               option of the enrollee or subscriber, does one of the  
               following:
                
                d. Page 39, lines 22-26:
                (i) Commencing January 1, 2007, an individual enrolled  
               in Medicare Part B is entitled to open enrollment  
               described in this section upon being notified that he  
               or she is no longer eligible for benefits,  including   
               or only eligible for benefits with a share of cost,  
               under the Medi-Cal program because of an increase in  
               the individual's income or assets.

                e. Page 99, lines 38-40, Page 100, lines 1-2:  
                (i) Commencing January 1, 2007, an individual enrolled  
               in Medicare Part B is entitled to open enrollment  




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               described in this section upon being notified that he  
               or she is no longer eligible for benefits,  including   
               or only eligible for benefits with a share of cost,  
               under the Medi-Cal program because of an increase in  
               the individual's income or assets.

                f. Page 26, lines 38-40, Page 27, lines 1-6: 
                (c) Benefit plans shall be uniform in structure,  
               language, designation and format to the standard  
               benefit plans A to L  J  , inclusive, listed in  
               subdivision (e), and shall conform to the definitions  
               in Section 1358.4. Each benefit shall be structured in  
               accordance with the format provided in subdivisions  
               (b), (c), (d), and (e) of Section 1358.8 and list the  
               benefits in the order listed in subdivision (e). For  
               purposes of this section, "structure, language, and  
               format" means style, arrangement, and overall content  
               of a benefit.


                g. Page 87, lines 7-15:
                (c) Benefit plans shall be uniform in structure,  
               language, designation and format to the standard  
               benefit plans A to L  J  ,, inclusive, listed in  
               subdivision (e), and shall conform to the definitions  
               in Section 10192.4. Each benefit shall be structured  
               in accordance with the format provided in subdivisions  
               (b), (c), (d), and (e) of Section 10192.8 and list the  
               benefits in the order listed in subdivision (e). For  
               purposes of this section, "structure, language, and  
               format" means style, arrangement, and overall content  
               of a benefit.

                h. Page 40, lines 11-16:
                (1) The individual is enrolled under an employee  
               welfare benefit plan that provides health benefits  
               that supplement the benefits under Medicare, the plan  
               either terminates or ceases to provide all of those  
               supplemental health benefits to the individual,  and  or  
               the employer no longer provides the individual with  
               insurance that covers all of the payment for the  
               20-percent coinsurance.

                i. Page 100, lines 25-30:
                (1) The individual is enrolled under an employee  




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               welfare benefit plan that provides health benefits  
               that supplement the benefits under Medicare, the plan  
               either terminates or ceases to provide all of those  
               supplemental health benefits to the individual,  and  or  
               the employer no longer provides the individual with  
               insurance that covers all of the payment for the  
               20-percent coinsurance.

                j. Page 50, lines 3-5:
                (ii) The cover page shall contain the 14-plan  12-plan   
               (A-L) charts. The plans offered by the issuer shall be  
               clearly identified. Innovative benefits shall be  
               explained in a manner approved by the director.

                k. Page 112, lines 10-13:
                (II) The cover page shall contain the 14-plan  12-plan   
               (A-L) charts. The plans offered by the insurer shall  
               be clearly identified. Innovative benefits shall be  
               explained in a manner approved by the commissioner.  
               The text shall read:

                l. Page 84, lines 29-40, Page 85, lines 1-2: 
                (b) With respect to the standards for basic (core)  
               benefits for benefit plans A, B, C, D, F, F with high  
               deductible high deductible F, G, M, and N, every  
               issuer of Medicare supplement insurance benefit plans  
               shall make available a policy or certificate including  
               only the following basic "core" package of benefits to  
               each prospective insured. An issuer may make available  
               to prospective insureds any of the other Medicare  
               Supplement Insurance Benefit Plans in addition to the  
               basic (core) package, but not in lieu of it. However,  
               the benefits described in paragraphs  (6) and  (7) and  
               8) shall not be offered so long as California is  
               required to disallow these benefits for Medicare  
               beneficiaries by the centers for Medicare and Medicaid  
               Services or other agent of the federal government
               under Section 1395ss of Title 42 of the United States  
               Code.
                
               m. Page 123, lines 36-39:
                (B) For policies sold for effective dates on or after  
               June 1, 2010, a listing of all the policies, plans, A  
               to D, inclusive, F,  F with  high deductible F, G, and K  
               to N, inclusive, for Medicare beneficiaries under the  




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               age 65 that are available from the company.


                                    POSITIONS  
                                        
          Support:  California Department of Insurance (sponsor)
                 America's Health Insurance Plans

          Oppose:  None received


                                   -- END --