BILL ANALYSIS                                                                                                                                                                                                    



                                                                  AB 2315
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          Date of Hearing:  March 23, 2010

                           ASSEMBLY COMMITTEE ON JUDICIARY
                                  Mike Feuer, Chair
                 AB 2315 (Conway) - As Introduced: February 19, 2010
                                           
          SUBJECT  :  INJURED PERSONS:  PERSONAL IDENTIFYING INFORMATION

           KEY ISSUES  :

          1)SHOULD INJURED PERSONS BE REQUIRED TO PROVIDE SOCIAL SECURITY  
            NUMBERS AND OTHER PERSONAL IDENTIFYING INFORMATION WHEN  
            NOTIFYING PUBLIC AGENCIES OF POTENTIAL CLAIMS?  

          2)HAS THE NEED FOR THIS BILL BEEN DEMONSTRATED IN LIGHT OF  
            FEDERAL RULES THAT APPEAR TO INDICATE THAT IT IS UNNECESSARY  
            AND OVERBROAD, COULD UNFAIRLY PRECLUDE INJURED PERSONS FROM  
            SEEKING A REMEDY FOR THEIR INJURIES, AND POTENTIALLY INCREASES  
            PRIVACY RISKS? 

           FISCAL EFFECT  :  As currently in print this bill is keyed  
          non-fiscal.

                                      SYNOPSIS
          
          This bill would amend the process by which injured persons seek  
          a remedy for claims against the government.  Existing law  
          requires that these claims be presented to the responsible  
          public agency prior to any legal action, and prescribes the  
          timing and content of that notice.  This bill would add to that  
          notice the requirement that the injured person supply their  
          social security number and other personal identifying  
          information upon request, ostensibly to allow the public agency  
          to determine whether the claimant has received Medicare benefits  
          for their injury for the purpose of coordinating insurance and  
          Medicare payments.  Although the sponsor, representing joint  
          powers authorities, believes that the bill is necessary in order  
          to allow public entities to timely and accurately comply with  
          federal law, the available information does not appear to  
          corroborate that concern.  Moreover, the bill appears to be  
          significantly broader in scope than any federal requirement.   
          The bill may also inadvertently create potential obstacles to  
          recovery for injured persons, as well as the risk of privacy  
          intrusions and identity theft.
           








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          SUMMARY  :  Requires sensitive personal information to be provided  
          to the government by crime victims, businesses, and others who  
          have claims for injury against state and local government  
          agencies.  Specifically,  this bill  amends the pre-suit  
          government claims presentment rule to mandate that:

          1)Upon request of the public entity or its representative, a  
            claimant whose claim includes past or future medical treatment  
            shall provide his or her social security number, Medicare  
            health insurance claim number (HICN), any alternate name, date  
            of birth, and gender within 30 days of the request.

          2)Additionally, upon request of the public entity or its  
            representative, the claimant shall complete the Medicare  
            Beneficiary Inquiry Form.           

           EXISTING LAW  :  

           1)Requires certain claims for money or damages by crime victims,  
            persons injured by governmental negligence and those alleging  
            breach of an express contract against the state, local  
            government entities, and entities of the judicial branch to be  
            presented to the governmental entity prior to suit, setting  
            forth the claimant's name, address, and the circumstances  
            giving rise to the claim.  (Government Code sections 905,  
            905.2, 905.7, 910.)  Further statutory references are to this  
            code unless otherwise noted.)

          2)Bars any claimant from filing suit if the required government  
            presentment is not made or is incomplete or inaccurate.   
            (Sections 910.6, 910.8, 911, 945.4.)

          3)Restricts the unnecessary collection and misuse of Social  
            Security numbers in order to protect individuals' right to  
            privacy and to minimize the opportunities for identity theft.   
            (E.g., Civil Code section 1798.85; Government Code sections  
            27300 and 27301.)

          4)Restricts the collection of sensitive identifying information  
            in medical records.  (E.g., Civil Code sections 56 et seq.,  
            1798.91.)

           COMMENTS  :  The author maintains that the bill is needed for the  
          following reasons:









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               A new federal law became effective January 1, 2009  
               establishing Section 111 of the Medicare, Medicaid and  
               SCHIP Extension Act of 2007 (MMSEA).  This law now requires  
               expanded reporting by liability insurers (including  
               self-insurers), no-fault insurers, and workers'  
               compensation plans about Medicare beneficiaries seeking  
               past or future medical treatment who have other insurance  
               coverage.  The additional items of information are the  
               claimant's Medicare health insurance claim number (HICN) or  
               social security number [SSN], any alternate name used by  
               the claimant, the claimant's date of birth and the gender  
               of the claimant.

               The expanded claimant information assists the Centers for  
               Medicare & Medicaid Service (CMS) and other insurance plans  
               to coordinate payment of benefits among insurance plans so  
               that claims are paid promptly and correctly.  Failure to  
               report, or to correctly report, claimant information to CMS  
               exposes public entities to fines of $1,000 per day per  
               claim.    

               Today, California law (Government Code 910) requires  
               claimants to supply their name, address, date of claim, the  
               circumstances of the claim, and estimated amount of claim.   
               However, Government Code 910 does not require the claimant  
               to include the expanded list of information needed by  
               public entities to correctly comply with the federal  
               changes.

          The sponsor, the California Association of Joint Powers  
          Authorities (CAJPA), argues that it is necessary to amend  
          Government Code section 910 to authorize public entities to  
          collect the additional information from claimants who seek past  
          or future medical treatment as part of their claim against a  
          public entity in order to correctly comply with Section 111 of  
          the Medicare, Medicaid and SCHIP Extension Act of 2007 (MMSEA).   
          CAJPA states that this change in statute will permit public  
          entities to correctly comply with federal reporting requirements  
          in a timely fashion, and will reduce public entity exposure to  
          large fines and penalties for failing to correctly report  
          claimant information.

           Background on Federal Medicare Reporting Law  .  Federal law has  
          long required coordination of Medicare benefits among the  
          federal government and any insurance payments, and has required  








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          that covered insurers report to the Medicare program when they  
          make payments to persons who received Medicare benefits so that  
          the federal government can seek reimbursement, if possible.   
          According to federal court documents provided by the sponsors:

               All Medicare payments [to beneficiaries] are conditioned on  
               reimbursement if it is demonstrated that a primary plan had  
               responsibility to pay for those medical expenses.  42  
               U.S.C.  1395y(b)(2)(B); 42 C.F.R.  411.24.  Although that  
               obligation has existed since 1980, Congress clarified its  
               intent of shifting the burden to private parties with its  
               amendments to the [Medicare Secondary Payer] Statute in  
               2003, which define "primary plan" to include a plan of  
               self-insurance, specifying that "[a]n entity that is  
               engaged in a business, trade, or profession shall be deemed  
               to have a self-insured plan if it carries its own risk  
               (whether by a failure to obtain insurance, or otherwise),  
               in whole or in part."  42 U.S.C.  1395y(b)(2)(A)(ii); see  
               also 42 C.F.R.  411.50(b).  The primary plan's  
               responsibility to make primary payment may be demonstrated  
               by "a payment conditioned on the recipient's . . . release  
               (whether or not there is a determination or admission of  
               liability) of payment." 42 U.S.C.  1395y(b)(2)(A)(ii).  

          (Memorandum In Support Of The United States' Motion For Partial  
          Summary Judgment On Liability, U.S. v. Stricker, No.  
          CV-09-KOB-2423-E (N.D. Ala., filed Jan, 28, 2010).  

          A 2007 law, effective last year - Section 111 of the Medicare,  
          Medicaid, and SCHIP Extension Act of 2007 (MMSEA) (P.L.110-173)  
          - added new mandatory reporting requirements for certain  
          insurance plans, including certain self-insurers.  (See  
          http://www.cms.hhs.gov/mandatoryinsrep.)
          Under this law, covered self insurers may be required to report  
          additional information regarding payments made to Medicare  
          beneficiaries after verdicts and settlements of legal claims.  

          Although the sponsor appears to believe that this bill is  
          necessary in order to allow public entities to timely and  
          accurately comply with federal law, the available information  
          does not appear to validate that concern.

           At Most, Federal Law Appears To Require Only That Certain  
          Information Be Requested - Not Required.   Section 111 appears to  
          request reporting of SSN and other information indicated by the  








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          sponsor.  However, contrary to the sponsors' understanding,  
          section 111 does not require that this information be reported.   
          Rather, the law provides a "safe harbor" by which covered  
          entities may simply ask claimants to complete an inquiry form,  
          which the claimant is authorized to decline.  Guidance provided  
          by the Centers for Medicare & Medicaid Service (CMS) states:   

                If an individual refuses to furnish either a HICN or SSN,  
               and the ? reporting entity chooses to use the attached  
               model language, CMS will consider the reporting entity  
               compliant? even if the individual is later discovered to be  
               a Medicare beneficiary. 

          http://www.cms.hhs.gov/MandatoryInsRep/Downloads/ALERTComplianceH 
          ICNSSNsNGHP082409.pdf

          This model language form expressly allows the claimant to refuse  
          to fill it out.  (See  
          http://www.gpatpa.com/PDF/CMS_ALERT_and_Model_form_for_collecting 
          _SSN.pdf.)  

          The law firm of Wiley Rein LLP firm has published an article on  
          its web site noting:

               It appears certain that many claimants will simply ignore  
               or refuse to sign or return the form.  Claimants have  
               little or no incentive to provide the requested information  
               to liability insurers or self-insured entities, and in some  
               circumstances they arguably have an incentive not to make  
               the disclosure.  Indeed, CMS implicitly acknowledges that  
               Medicare law imposes no legal obligation on claimants to  
               provide the requested personal information, and without  
               apparent irony has provided a space on the form for the  
               claimant to explain the "Reason(s) for Refusal to Provide  
               Requested Information."  Many observers believe that large  
               numbers of claimants, however, will provide no such  
               explanation and instead will simply ignore the request --  
               leaving the requesting entity with no signed copy of the  
               form.  

               In a town-hall teleconference on September 30, 2009, CMS  
               representatives appeared to depart from the written  
               guidance contained in the CMS Alert, and implied that the  
               safe harbor might extend more broadly if the insurer could  
               prove that it has a "process" in place to obtain  








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               information from claimants and could prove delivery of the  
               request form to a specific claimant by certified mail or  
               otherwise. 

          (See  
          http://www.wileyrein.com/publications.cfm?sp=articles&id=5716.)

           If Federal Law Does Require Reporting Of The Information  
          Mandated By This Bill, The Information Is Not Required To Be  
          Reported Until After A Self-Insured Entity Has Paid The Claimant  
          - Not At The Point When The Claim Is Simply Being Considered  .   
          To the extent that federal law does require reporting of the  
          specified information under this bill, the reporting obligation  
          applies only after a claim has been paid - not at the initial  
          presentment stage when a claim is simply being evaluated and  
          considered by the covered entity.  This point is made explicit  
          in the statute, which states:  "Information shall be submitted  
          under subparagraph (A)(ii) within a time specified by the  
          Secretary after the claim is resolved through a settlement,  
          judgment, award, or other payment (regardless of whether or not  
          there is a determination or admission of liability).  (42 U.S.C.  
          section 1395y(b)(8)(C).)"  Of course, many claims against the  
          government are never paid, and relatively few are voluntarily  
          paid at the presentment stage.  Thus there may be no need for  
          the information in many cases.

          Despite the clear instruction of the statute, the sponsor has  
          suggested that covered entities must obtain the required  
          information prior to settlement in order to determine whether  
          the claimant received Medicare benefits.  They contend this is  
          necessary because they must demonstrate to the federal  
          government that they gave "adequate consideration" to Medicare's  
          interest in reaching a settlement or potentially be responsible  
          for the entire amount if Medicare officials deem the settlement  
          "unreasonable."  The sponsor cites oral statements by unnamed  
          CMS staff for this contention, but no written source, and  
          Committee staff have not been able to confirm that the sponsor's  
          understanding is accurate.  Indeed, it appears to be  
          contradicted by the statute and accompanying guidance materials.  
           However, if in fact the amount of Medicare payments were needed  
          to demonstrate that a settlement payment was reasonable, nothing  
          in current law would appear to prohibit a public entity from  
          conditioning its payment on the receipt of information about the  
          claimant's Medicare benefits - or at least requesting the  
          safe-harbor form described above.








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           It Is Not Clear That Federal Reporting Obligations Apply To  
          Self-Insured Public Entities.  The ostensible need for this bill  
          is predicated on the sponsor's belief that self-insured public  
          entities are among the entities covered by the reporting  
          obligation.  However, there is some question on this issue  
          because guidance published by CMS appears to suggest that only  
          self-insurers "engaged in a business, trade or profession" are  
          covered.

               Pursuant to 42 C.F.R. Part 411.50: "Liability insurance  
               means insurance (including a self-insured plan) that  
               provides payment based on legal liability for injury or  
               illness or damage to property. It includes ? liability  
               insurance payment[s] ? by any individual or other entity  
               that carries liability insurance or is covered by a  
               self-insured plan."  See Appendix G for the CMS definition  
               of "self-insurance." Essentially, individuals/entities  
                engaged in a business, trade, or profession  are  
               self-insured to the extent they have not purchased  
               liability insurance coverage. 

          (Centers for Medicare & Medicaid Services, Liability Insurance  
          User Guide, p. 14-15 (available at  
          http://www.cms.hhs.gov/MandatoryInsRep/Downloads/NGHPUserGuideV30 
          22210.pdf).)

          If all self-insured public agencies are covered, it is somewhat  
          surprising that no other governmental entity or association has  
          joined the sponsor in support of the bill, despite the sponsor's  
          observation that most local public entities in California are  
          self-insured.

           If Self-Insured Governmental Entities Are Required To Report  
          Information To Medicare, This Bill Nevertheless Appears To Be  
          Overbroad By Covering Many Governmental Entities, Many Types Of  
          Individual Claimants, And Many Types Of Claims That Are Not  
          Covered By Federal Reporting Requirements  .  This bill would  
          amend the government claims presentment statute that applies to  
          all public entities, including the state and the judicial  
          branch, not only those that may be self-insured.  The statute  
          also covers all claimants, not simply those who have received  
          payments from Medicare (i.e., enrolled persons over 65 years of  
          age and certain persons with disabilities).  And the statute  
          covers all types of claims, including crime victim compensation  








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          and claims for breach of contract.  Consequently, the bill  
          appears to sweep much more broadly than any Medicare reporting  
          requirement.

           If A Crime Victim Or Other Injured Person Failed To Comply With  
          This Bill The Apparent Penalty Would Be The Total Loss Of Any  
          Right To Seek Redress.   The failure to comply with the mandate  
          of this bill would preclude the injured person from any recovery  
          for their injury because existing law bars any claimant from  
          filing suit if the required government presentment is not made  
          or is incomplete or inaccurate.  (See Sections 910.6, 910.8,  
          911, 945.4.)

           The Personal Identifying Information Required To Be Provided By  
          This Bill Is Sensitive And Creates Significant Risks To Privacy  
          Rights.   As this Committee has often heard in recent years,  
          social security numbers are one of the most sensitive personal  
          identifiers because they are one of the three pieces of  
          information most often sought by identity thieves.  The  
          collection of social security numbers has inevitably lead to  
          frequent inadvertent disclosures, putting the subjects at risk  
          of identity theft and invasion of privacy.  As a result,  
          California has taken the lead in legislation to protect against  
          the unnecessary use and storage of this information by both  
          businesses and governmental agencies.  By adding a new  
          requirement to provide social security numbers, this bill  
          appears to go in the opposite direction.

           ARGUMENTS IN OPPOSITION:   The ACLU writes in opposition to the  
          bill, stating:
           
                California has taken the lead in protecting against the  
               unnecessary collection and misuse of Social Security  
               numbers in the interest of protecting individuals' right to  
               privacy and to minimize the opportunities for identity  
               theft.  (See, for example, Civil Code section 1798.85, and  
               Government Code sections 27300 and 27301.)  
               In spite of the clear policy against unnecessary collection  
               and use of Social Security Numbers, AB 2315 would impose a  
               requirement to authorize public entities to gather SSNs as  
               part of an individual's claim under the tort claims act - a  
               publicly available record.  This requirement appears to be  
               both unnecessary and risks exposing people's sensitive SSNs  
               to the public.  While AB 2315 asserts that the Social  
               Security will assist with a federal reporting requirement,  








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               it is not required by the statute (See, 42 U.S.C. Sec.  
               1395y(b)(8).)  

          In addition, the Consumer Attorneys of California states:

               This bill unnecessarily requires injured consumers to  
               prematurely disclose personal information, including their  
               Social Security number, and date of birth to a defendant  
               public entity at the presentment stage of a claim.  Current  
               law, Gov. Code Sec. 910, requires claimants to submit only  
               their name, address, the circumstance of their injury, and  
               an estimated amount for the government tort claim.  While  
               it is true that federal law requires additional information  
               to be collected from a claimant, the law requires this  
               information only in cases where claims have been resolved.   
               42 U.S.C. Sec. 1395y(b)(8)(C).  It can take years to  
               resolve a claim, it is unnecessary for a plaintiff to have  
               to provide this information to the defendant within 30 days  
               of presenting a claim.  In most cases, once the case  
               proceeds through the adjudicative process, good cause for  
               discovery will exist and the defendant will be able to  
               request the information at this point. 

               AB 2315 is also overinclusive.  There is no reason why  
               claimants who are not on and will not forseeably be on  
               Medicare should have to comply with these invasive  
               requirements.  AB 2315 would potentially allow the  
               government to request this information from any and all  
               claimants, regardless of whether they are in fact, on  
               Medicare and subject to the CMA reporting requirements.  
           
          REGISTERED SUPPORT / OPPOSITION  :   

           Support 
           
          California Association of Joint Powers Authorities

           Opposition 
           
          ACLU
          Consumer Attorneys of California
           
          Analysis Prepared by  :  Kevin G. Baker / JUD. / (916) 319-2334