BILL ANALYSIS                                                                                                                                                                                                    



                                                                       



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          |SENATE RULES COMMITTEE            |                  AB 2110|
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                                 THIRD READING


          Bill No:  AB 2110
          Author:   De La Torre (D)
          Amended:  5/12/10 in Assembly
          Vote:     21

           
           SENATE HEALTH COMMITTEE  :  5-2, 6/30/10
          AYES:  Alquist, Cedillo, Leno, Pavley, Romero
          NOES:  Strickland, Aanestad
          NO VOTE RECORDED: Cox,  Negrete McLeod

           SENATE APPROPRIATIONS COMMITTEE  :  Senate Rule 28.8

           ASSEMBLY FLOOR :  47-27, 6/2/10 - See last page for vote


           SUBJECT  :    Health care coverage:  premium payments:  grace  
          periods

           SOURCE  :     Health Access


           DIGEST  :    This bill requires health insurance policies and  
          health care service contracts, issued, amended, or renewed  
          on or after January 1, 2011, to provide a grace period of  
          50 days for the payment of each premium falling due after  
          the first premium, during which the policy continues in  
          force, and makes enrollees and insureds, if they fail to  
          pay the premium owed during the grace period, liable for  
          any medical costs incurred during the grace period, except  
          as specified.

           ANALYSIS  :    
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           Existing law  

          1. Provides for the regulation of health plans and insurers  
             by the Department of Managed Health Care (DMHC) and the  
             California Department of Insurance (CDI), respectively.

          2. Requires existing insurance policies regulated by CDI to  
             include a provision setting forth a grace period for  
             making premium payments, in specified formats.

          3. Requires the grace period to be no less than seven days  
             for weekly premium policies, no less than ten days for  
             monthly premium policies, and no less than thirty-one  
             days for all other policies.

          4. Prohibits the Insurance Commissioner from approving a  
             policy for issuance or delivery, and authorizes the  
             Commissioner to withdraw approval for a policy, if it  
             fails to meet these requirements.

          This bill:

          1. Requires individual health insurance policies and  
             individual health plan contracts, issued, amended, or  
             renewed on or after January 1, 2011, to provide a grace  
             period of 50 days for the payment of each premium  
             falling due after the first premium, during which the  
             policy continues in force.  

          2. Makes enrollees and insureds, if they fail to pay the  
             premium owed during the grace period, liable for any  
             medical costs incurred during the grace period, except  
             as specified.

          3. Requires health plans and insurers, upon issuance,  
             amendment, or renewal of an individual contract or  
             policy, to provide a notice to the enrollee or insured  
             of the grace period, as specified.  

          4. Prohibits this bill from limiting the right of health  
             plans and insurers to recover unpaid premiums from an  
             enrollee or insured consistent with state and federal  
             law.  

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           Background
           
           Blue Shield's changes in grace period policy  .  On December  
          16, 2009, an article appeared in the Los Angeles Times  
          regarding Blue Shield's change in its grace period policy  
          for products in the individual market.  According to the  
          article, Blue Shield sent a letter to their policyholders  
          notifying them that, effective January 1, 2010, coverage  
          could be immediately dropped if a payment is missed.  If  
          dropped, customers could reapply for coverage, but could be  
          declined based upon the customer's medical condition.  The  
          article also reported that by Blue Shield reducing their  
          grace period from 43 days to 28 days, Blue Shield was  
          taking "a key benefit" away.  According to a Blue Shield  
          spokesman who was quoted in the article, the change was  
          meant to "make everything uniform," but that the grace  
          period policy was not changing.  In comparison, the article  
          cited Kaiser Permanente's policy of offering a 50-day grace  
          period before a policy is canceled.  According to Kaiser,  
          which has no position on this bill, if a member has been  
          terminated more than 3 times in a 12-month period for  
          non-payment of premiums, the member must wait 12 months to  
          reapply and must undergo a medical screening.  Anthem Blue  
          Cross has publicly stated that it will not offer any more  
          than the state mandated grace period.  

           NAIC standard grace period  .  The National Association of  
          Insurance Commissioners (NAIC), which provides a forum for  
          the development of uniform policy when appropriate, has  
          adopted model law provisions related to grace periods.  The  
          Uniform Individual Accident and Sickness Policy Provision  
          Law includes the following grace period language:  "A grace  
          period of [insert a number not less than 7 for weekly  
          premium policies, 10 for monthly premium policies and 31  
          for all other policies] days will be granted for the  
          payment of each premium falling due after the first  
          premium, during which grace period the policy shall  
          continue in force."

          The grace period language in NAIC's Group Health Insurance  
          Standards Model Act states:  "A provision that the  
          policyholder is entitled to a grace period of [insert a  
          number not less than 7 for weekly premium policies, 10 for  

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          monthly premium policies and 31 for all other policies]  
          days for the payment of any premium due except the first.   
          During the grace period the policy shall continue in force,  
          unless the policyholder has given the insurer written  
          notice of discontinuance in advance of the date of  
          discontinuance and in accordance with the terms of the  
          policy.  The policy may provide that the policyholder shall  
          be liable to the insurer for the payment of a pro rata  
          premium for the time the policy was in force during the  
          grace period."

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

           SUPPORT  :   (Verified  6/30/10)

          Health Access (source)
          AARP 
          America Federation of State, County and Municipal Employees
          California Chiropractic Association
          California Labor Federation 
          California Medical Association 
          Consumers Union
          JERICHO 
          Planned Parenthood of California 
          Planned Parenthood Mar Monte
          Planned Parenthood: Shasta-Diablo

           OPPOSITION  :    (Verified  6/30/10)

          America's Health Insurance Plans 
          Association of California Life & Health Insurance Companies  

          California Association of Health Plans 
          California Association of Health Underwriters
          California Chamber of Commerce
          Health Net 
          Irvine Chamber of Commerce
          Sacramento Metropolitan Chamber of Commerce

           ARGUMENTS IN SUPPORT  :    Health Access writes that there  
          have been reports of predatory behavior, in which insurers  
          are slow to give premium notices to consumers, then cancel  
          the policy for late payment and offer to provide new  

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          coverage only if the consumer passes medical underwriting.   
          Health Access states that, while the recently enacted  
          federal health reform will require guaranteed issue of  
          health insurance in 2014, there is nothing to prevent  
          insurers from providing consumers unreasonably short notice  
          of overdue premiums and using this as an excuse to drop  
          sick customers and keep healthy ones in the meantime. 

          The California Labor Federation writes that, in the current  
          economic downturn, families are struggling to make ends  
          meet and pay for basic necessities. The California Labor  
          Federation states that the extra days that this bill  
          provides will give families the time to scrape together  
          payments to keep their insurance that protects them from  
          additional hardship in the case of an accident or sickness.  
           

          A number of patient advocacy organizations, including AARP  
          and Consumers Union, write in support, stating that, in  
          this period of economic uncertainty, people sometimes need  
          extra time to be able to make payments and keep coverage.  

          Various provider groups, such as the California Medical  
          Association and the California Chiropractic Association,  
          states that this bill will add some flexibility to the  
          current grace period so that consumers have an adequate  
          opportunity to make payments and keep coverage.

           ARGUMENTS IN OPPOSITION  :    The Association of California  
          Life and Health Insurance Companies (ACLHIC) states that,  
          under this bill, costs will rise for consumers in  
          California because the health insurer will be forced to  
          absorb the additional costs, or providers will look for  
          ways to recover the unpaid payments.  ACLHIC asserts that  
          by increasing the grace period to 50 days, the frequency of  
          unpaid care will increase, and therefore result in a cost  
          shift to providers or the consumers.  America's Health  
          Insurance Plans (AHIP) writes that the grace periods  
          currently required by California law are in line with  
          national standards of consumer protection, including NAIC  
          model laws, which were carefully calculated not only to  
          ensure that policyholders are able to continue receiving  
          care, but to protect them from the pitfalls of falling  
          behind on premium payments.  AHIP further states that,  

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          while it may seem helpful to extend grace periods, there  
          are unfortunately often circumstances when an individual is  
          unable to become current on their premium payments after  
          entering the grace period.  AHIP states that, for these  
          individuals, it is even less likely that they will be able  
          to repay past premiums while "catching up" to pay current  
          premiums.

          Health Net opposes this bill , arguing that, by extending  
          the grace period to 50 days, the bill will lead to health  
          plans and insurers absorbing the additional cost of  
          uncompensated care, the cost of which will be made up in  
          the form of higher premiums paid by other insureds and  
          enrollees.  Contrary to the author's statements, Health Net  
          believes that the bill does not make an enrollee or  
          insured, who ultimately fails to pay their premium, liable  
          for their medical expenses incurred during the grace  
          period, as this provision does not apply when the medical  
          service is authorized by the plan or insurer.  This does  
          not provide any meaningful protection for health plans or  
          insurers, since health plans and insurers continue to  
          authorize treatment during the grace period; to do  
          otherwise would not be in the best interest of Californians  
          covered in the individual market.  

          The California Association of Health Plans asserts that  
          this bill would increase health costs for all consumers, as  
          the cost of care provided during the extended grace period  
          must be taken into account by the plan.  The California  
          Association of Health Underwriters also points out that the  
          current standard for all but a few products is 31 days, and  
          that 50 days is arbitrary.

          The California Chamber of Commerce opposes this bill,  
          stating that it could further exacerbate California's  
          budget crisis by increasing health insurance costs at a  
          time that this state is still struggling through an  
          economic crisis, evidenced by one of the highest  
          unemployment rates in the nation. 
           
          ASSEMBLY FLOOR  : 
          AYES:  Ammiano, Arambula, Bass, Beall, Block, Blumenfield,  
            Bradford, Brownley, Buchanan, Caballero, Carter, Chesbro,  
            Coto, Davis, De La Torre, De Leon, Eng, Evans, Feuer,  

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            Fong, Fuentes, Furutani, Galgiani, Hall, Hayashi,  
            Hernandez, Hill, Huffman, Jones, Bonnie Lowenthal, Ma,  
            Mendoza, Monning, Nava, V. Manuel Perez, Portantino,  
            Ruskin, Salas, Saldana, Skinner, Solorio, Swanson,  
            Torlakson, Torres, Torrico, Yamada, John A. Perez
          NOES:  Adams, Anderson, Bill Berryhill, Blakeslee, Conway,  
            Cook, DeVore, Emmerson, Fletcher, Fuller, Gaines,  
            Garrick, Gilmore, Hagman, Harkey, Huber, Jeffries,  
            Knight, Logue, Miller, Nestande, Niello, Nielsen, Silva,  
            Smyth, Tran, Villines
          NO VOTE RECORDED:  Tom Berryhill, Charles Calderon, Lieu,  
            Norby, Audra Strickland, Vacancy


          CTW:do  8/2/10   Senate Floor Analyses 

                         SUPPORT/OPPOSITION:  SEE ABOVE

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