BILL ANALYSIS                                                                                                                                                                                                    �



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        CONCURRENCE IN SENATE AMENDMENTS
        AB 922 (Monning)
        As Amended September 2, 2011
        Majority vote
         
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        |ASSEMBLY:  |51-27|(June 2, 2011)  |SENATE: |21-12|(September 7,  |
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        |COMMITTEE VOTE:  |10-4 |(September 7, 2011) |RECOMMENDATION: |concur    |
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        Original Committee Reference:   HEALTH  

         SUMMARY  :  Transfers the Department of Managed Health Care (DMHC) 
        from the Business, Transportation and Housing Agency (BT&H) to the 
        California Health and Human Services Agency (CHHSA).  Transfers the 
        Office of the Patient Advocate (OPA) from DMHC to CHHSA effective 
        July 1, 2012, and requires existing OPA duties to apply to health 
        insurers regulated by the Department of Insurance (DOI) and their 
        insureds (in addition to DMHC-regulated health plans).  Assigns new 
        duties to OPA related to assisting consumers obtain public and 
        private health care coverage and navigate public and private 
        coverage consistent with requirements under the Patient Protection 
        and Affordable Care Act (PPACA).

         The Senate amendments  :

        1)Transfer DMHC from BT&H to CHHSA.

        2)Transfer OPA from DMHC to CHHSA effective July 1, 2012.

        3)Make the provisions affecting insureds covered by health insurers 
          regulated by DOI and individuals who receive or are eligible for 
          coverage under Medi-Cal Program, the California Health Benefit 
          Exchange (Exchange), the Healthy Families Program (HFP), or any 
          other county or state health care program effective January 1, 
          2013, and specify that for the period July 1, 2012, through 
          January 1, 2013, OPA will continue with any duties, 
          responsibilities or activities in place as of July 1, 2011.








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        4)Require OPA to consult with DMHC, DOI, the Managed Risk Medical 
          Insurance Board (MRMIB), the Department of Health Care Services 
          (DHCS), and the Exchange in developing consumer educational and 
          information guides.

        5)Commencing January 1, 2013:

           a)   Require OPA to adopt standards for the organizations with 
             which it contracts to ensure compliance with the privacy and 
             confidentiality laws, as specified;

           b)   Require OPA to conduct privacy trainings as necessary, and 
             regularly verify that the organizations have measures in place 
             to ensure compliance with this provision;

           c)   Require OPA to coordinate with other state and federal 
             agencies engaged in outreach and education regarding the 
             implementation of federal health reform;

           d)   Require OPA to refer consumers to the appropriate regulator 
             of health coverage program for filing complaints, and 
             grievances, claims or payment problems; and,

           e)   Permit OPA to provide grants to community-based consumer 
             assistance organizations for portions of its functions.

        6)Delete detailed data reporting provisions and instead require, 
          commencing January 1, 2013:

           a)   OPA to track and analyze data on problems and complaints by 
             and questions from consumers about health care coverage for 
             the purpose of providing public information about problems 
             faced and information needed by consumers in obtaining 
             coverage and care;

           b)   Data collected to include demographic data, source of 
             coverage, regulator, and resolution of complaints, including 
             timeliness of resolution;

           c)   OPA to collect and report data to the United States 
             Secretary of Health and Human Services (HHS) on complaints and 
             consumer assistance as required to comply with requirements of 
             PPACA;









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           d)   DMHC, DHCS, DOI, MRMIB, the Exchange, and other public 
             coverage programs to provide to the office data in the 
             aggregate concerning consumer complaints and grievances;

           e)   OPA, for the purpose of publicly reporting information 
             about the problems faced by consumers in obtaining care and 
             coverage, to analyze data on consumer complaints and 
             grievances resolved by these agencies, including demographic 
             data, source of coverage, insurer or plan, resolution of 
             complaints and other information intended to improve health 
             care and coverage for consumers; and,

           f)   OPA to develop and provide comprehensive and timely data 
             and analysis based on the information provided by other 
             agencies.  

        7)Delete detailed provisions related to the development of 
          protocols and procedures and instead require OPA to develop: 

           a)   A procedure for referral of complaints and grievances to 
             the appropriate regulator or health coverage program for 
             resolution by the relevant regulator or public program; and,

           b)   A protocol or procedures for reporting to the appropriate 
             regulatory and health coverage program regarding complaints 
             and grievances relevant to that agency that the OPA received 
             and was able to resolve without further action or referral.

        8)Delete further provisions that:

           a)   Give OPA access to records of DOI and sunset the access to 
             DMHC records on January 1, 2013;

           b)   Require OPA to provide education about how to navigate the 
             health care arena, as specified;

           c)   Require OPA to educate consumers on their rights and 
             responsibilities with respect to health care coverage;

           d)   Require OPA to advise and assist consumers with resolving 
             problems with obtaining premium tax credits under Section 36B 
             of the Internal Revenue Code;

           e)   Require OPA to implement and oversee a training program 
             with continuing education components for organizations with 








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             which it contracts;

           f)   Give OPA the power to revoke the contract of any 
             organization that violates specified standards and require OPA 
             to include a clause reserving that power in every contract 
             entered into with such an organization;

           g)   Require educational materials on health care coverage 
             options and how to resolve problems to be made available to 
             all consumer assistance programs and on the Internet Web site 
             of the OPA; and,

           h)   Define "group health plan."

        9)Define "health coverage program" to include the Medi-Cal Program, 
          HFP, tax subsidies and premium credits under the Exchange, the 
          Basic Health Program, if enacted, county health coverage 
          programs, and the Access to Infants and Mothers Program.  
         
        10)Permit, rather than require, OPA to apply to the Secretary of 
          HHS for a grant under PPACA.  
         
        11)Make other clarifying, conforming changes.

         AS PASSED BY THE ASSEMBLY , this bill transferred OPA from DMHC to 
        operate as an independent entity within state government, required 
        existing OPA duties to apply to health insurers regulated by DOI 
        and their insureds (in addition to DMHC-regulated health plans) and 
        assigned new duties to OPA consistent with requirements under 
        PPACA.

         FISCAL EFFECT  :  According to the Senate Appropriations Committee:

                            Fiscal Impact (in thousands)

         Major Provisions                2011-12     2012-13     2013-14   Fund
         OPA expansion                           unknown, potentially in the 
        hundreds       Special*
        and shift           of thousands of dollars

        OPA additional duties and                         likely in the 
        millions of dollars annually                      Special*
        ongoing administrationcommencing January 1, 2013

        DMHC data reporting      $0             about $250$500Special**








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        DOI data reporting       $0        $1,100         $550Special***

        DHCS, MRMIB, and                             unknown, potentially 
        significant    General/****
        Exchange data reporting                 commencing January 1, 
        2013Federal/
                                                     Special

        *Office of the Patient Advocate Trust Fund
        **Managed Care Fund
        ***Insurance Fund
        ****MRMIB costs shared 35% General Fund (GF), 65% federal funds; 
        Medi-Cal costs shared 50% GF, 50% federal funds Exchange costs paid 
        from the California Health Trust Fund; to the extent federal 
        financial participation is available.

         COMMENTS  :  According to the author, this bill establishes the OPA 
        in state government to position California to receive federal 
        monies made available by PPACA for the purpose of establishing and 
        operating such an office.  The author states California currently 
        has a fragmented system for consumer assistance with health care 
        coverage complaints.  The author states that there are currently 
        eight governmental entities and several private, non-profit 
        entities that provide a number of services to assist persons with 
        public and private health care coverage.  These services include 
        advice on coverage options, education about how to navigate the 
        system, assistance with complaints and grievances, and assistance 
        in choosing a health plan and finding a provider.  These entities 
        also respond to complaints about, among other things, eligibility, 
        coverage of services, and timely access to health care providers.  
        The author argues it is imperative that Californians be provided 
        with a single source of correct and current information on PPACA, 
        and that the OPA will also provide for much needed, clear and 
        understandable consumer information and assistance by expanding and 
        strengthening current programs operating at the local level that 
        will be consistent with the federal requirements for independence 
        and consumer orientation.  

        This bill also moves DMHC from BT&H to CHHSA.  According to the 
        author, this move makes sense for three reasons:

        1)The move is meant to create a clear internal chain of command for 
          the Administration.   DMHC's actions should be vetted through the 
          Health and Human Services Agency, which is focused on consumers 








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          and implementation of the Affordable Care Act (along with other 
          aspects of healthcare delivery and regulation), rather than BT&H, 
          which has no expertise in federal health care reform and its 
          requirements. 

        2)The state has a lot of obligations and changes to make under the 
          PPACA.  The Secretary of Health and Human Services should be 
          responsible for overseeing the state's progress on this, which 
          should include DMHC.  There are significant federal-state 
          relationships in other areas under HHS programs (such as 
          Medi-Cal, CalWORKs, and the Supplemental Nutrition Assistance 
          Program), and, the ACA is going to extend this federal-state 
          relationship even further.

        3)This bill moves the OPA to the Health and Human Services Agency.  
          Since its inception, the OPA and DMHC have been intertwined, with 
          much of OPA's focus being on the vast number of enrollees within 
          DMHC's purview.  If we move one, we should move the other. 

        California currently has a fragmented system for consumer 
        assistance with health care coverage complaints.  There are eight 
        governmental entities and several private, non-profit entities that 
        provide a number of services for assistance with public and private 
        health care coverage.  These services include advice on coverage 
        options, education about how to navigate the system, assistance 
        with complaints and grievances, assistance in choosing a health 
        plan, and finding a provider.  These entities also respond to 
        complaints about, among other things, eligibility, coverage of 
        services, and timely access to providers.  While these entities 
        exist to help consumers and purchasers of their specific services, 
        implementation of the PPACA will lead to millions of more 
        Californians enrolled in coverage, including expansions of public 
        programs.  Consumers will also have expanded choices of coverage 
        and different options to use, should they lose a source of 
        job-based coverage, have a child, divorce, or have an increase in 
        income.  
         

        Analysis Prepared by  :    Melanie Moreno / HEALTH / (916) 319-2097 


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