BILL ANALYSIS                                                                                                                                                                                                    �



                                                                      



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          |SENATE RULES COMMITTEE            |                  AB 1059|
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                                 THIRD READING


          Bill No:  AB 1059
          Author:   Huffman (D)
          Amended:  8/30/11 in Senate
          Vote:     21

           
           SENATE HEALTH COMMITTEE  :  8-1, 07/06/11
          AYES:  Hernandez, Strickland, Alquist, Blakeslee, De Le�n, 
            DeSaulnier, Rubio, Wolk
          NOES:  Anderson

           SENATE APPROPRIATIONS COMMITTEE  :  8-0, 08/25/11
          AYES:  Kehoe, Alquist, Emmerson, Lieu, Pavley, Price, 
            Runner, Steinberg
          NO VOTE RECORDED:  Walters

           ASSEMBLY FLOOR  :  49-26, 06/02/11 - See last page for vote


           SUBJECT  :    Health care service plans

           SOURCE  :     American College of Emergency Physicians, 
          California
                        Chapter


           DIGEST  :    This bill requires the director of the 
          Department of Managed Health Care (DMHC), upon making a 
          final determination that a health care service plan has 
          underpaid or failed to pay a provider, to compel the health 
          plan to pay the provider the amount owed, plus interest.

           ANALYSIS  :    Existing law:
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          1.Provides for the regulation of health plans by DMHC in 
            the Knox-Keene Health Care Service Plan Act of 1975 
            (Knox-Keene).

          2.Requires a health plan to pay claims, as specified, for 
            health care services provided as soon as practicable, but 
            no later than 30 working days after receipt of the claim 
            by a health plan, or if the health plan is a health 
            maintenance organization, no later than 45 working days 
            after receipt of the claim.  

          3.Prohibits a health plan from engaging in an unfair 
            payment pattern, and defines an "unfair payment pattern" 
            to mean any of the following:

                 Engaging in a demonstrable and unjust pattern of 
               reviewing or processing complete and accurate claims 
               that result in payment delays;
                 Engaging in a demonstrable and unjust pattern of 
               reducing the amount of payment or denying complete and 
               accurate claims;
                 Failing on a repeated basis to pay the uncontested 
               portions of any claim within timeframes required under 
               Knox-Keene; or
                 Failing on a repeated basis to automatically 
               include the interest due on claims that are not paid 
               within the 30 or 45 day timelines applicable for 
               uncontested claims.

          1.Prohibits a health plan from delegating its liability for 
            an unfair payment pattern to another entity, and 
            specifies that penalties due to an unfair payment pattern 
            shall not preclude, suspend, affect, or impact any other 
            duty, right, responsibility, or obligation under a 
            statute or under a contract between a health plan and a 
            provider.

          2.Provides, in regulations, that a health plan's failure to 
            comply with claims settlement laws and regulations may 
            constitute the basis for disciplinary action, and 
            authorizes the Director of DMHC to impose civil, 
            criminal, and administrative remedies in any combination.


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          3.Authorizes the Director to impose additional penalties 
            and remedies, including enhanced time periods for 
            processing claims or appointment of a claims monitor, for 
            a health plan the Director determines is engaged in a 
            demonstrable and unjust payment pattern.

          4.Authorizes the Director to suspend or revoke a Knox-Keene 
            license or assess administrative penalties, as specified, 
            if the Director determines that the licensee has 
            committed violations of Knox-Keene.  Also authorizes the 
            Director to assess civil penalties for any violation of 
            any Knox-Keene law or regulation, not to exceed $2,500 
            for each violation.

          5.Requires the Director, pursuant to regulations, when 
            assessing administrative penalties against a health plan, 
            to set the appropriate amount of the penalty for each 
            violation of Knox-Keene based on specified factors, 
            including but not limited to the following:

                 The nature, scope, and gravity of the violation;
                 The good or bad faith of the plan;
                 The health plan's history of violations;
                 The willfulness of the violation;
                 The nature and extent to which the health plan 
               cooperated with the DMHC's investigation;
                 The nature and extent to which the health plan 
               aggravated or mitigated any injury or damage caused by 
               the violation;
                 The nature and extent to which the health plan has 
               taken corrective action to ensure the violation will 
               not recur;
                 The financial status of the health plan;
                 The financial cost of the health care service that 
               was denied, delayed, or modified;
                 Whether the violation is an isolated incident; and
                 The amount of the penalty necessary to deter 
               similar violations in the future.

            1.  Establishes, pursuant to regulations, requirements 
              that health plans must implement in their claims 
              settlement practice, including timeliness standards for 
              the adjudication of complete claims, mandatory contract 
              provisions, mandated acknowledgements and disclosures 

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              and mandatory health plan provider dispute resolution 
              procedures.  

            2.  Prohibits a health plan from rescinding or modifying 
              an authorization for a specific type of treatment after 
              the provider renders the health care service in good 
              faith and pursuant to the health plan's authorization.

          This bill:

          1.Requires the Director, upon a final determination that a 
            health plan has underpaid or failed to pay a provider in 
            violation of Knox-Keene requirements related to unfair 
            payment practices, to require the health plan to pay the 
            provider an amount not less than the amount owed plus 
            interest.

          2.Prohibits a provider from being required to resubmit a 
            claim to a health plan in order to receive payment, 
            unless the Director (a) makes a determination that an 
            extraordinary circumstance exists, and (b) requires the 
            health plan to add to the amount owed to the provider a 
            reasonable amount necessary to reimburse the provider for 
            the cost of resubmission.

          3.Specifies that the remedies provided by this section are 
            not exclusive, and permits them to be sought and employed 
            in any combination with civil, criminal, and other 
            administrative remedies deemed warranted by the Director 
            to enforce health plan licensure provisions in statute.

          4.Requires the calculation of the amount of the penalty 
            imposed to be based on the date on which the health plan 
            committed the violation, as specified.

          5.Prohibits a health plan from being required to pay a 
            provider more than the amount owed plus interest on a 
            claim, and permits DMHC to take into account any other 
            payments that have been made on that same claim.

          6.Prohibits a health plan from delegating its statutory 
            liability under this bill.

          7.Clarifies that the intent of these provisions is to 

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            utilize DMHC's existing provider complaint resolution 
            process.
           
          Background
           
          Before the DMHC can begin a review, the provider is 
          required to submit the dispute to the health plan's Dispute 
          Resolution Mechanism, for a minimum of 45 working days or 
          until receipt of the health plan's written determination, 
          whichever period is shorter.  Claims not resolved through 
          the plan's process may be referred to DMHC's Provider 
          Complaint Unit (PCU), established in September 2004.    

          DMHC also has a six-month pilot Independent Dispute 
          Resolution Process (IDRP) to adjudicate claims disputes for 
          non-contracted providers of emergency hospital and 
          physician services for HMO enrollees in what DMHC refers to 
          as "a fast, fair, and cost-effective way to resolve claim 
          payment disputes with health care service plans and their 
          capitated providers."  The Maximus Center for Health 
          Dispute Resolution (CHDR) has been selected by the DMHC to 
          conduct an independent review and render the decisions in 
          provider payment disputes during the pilot program.  The 
          CHDR, a nationally accredited health appeals organization, 
          serves more than 25 other states in the role of reviewer of 
          appeals made by health plan enrollees, as well as 
          performing reviews for the federal Centers for Medicare and 
          Medicaid Services.  By submitting a claim dispute through 
          the IDRP, the provider agrees not to invoice, balance bill, 
          or otherwise seek to collect any payment from the health 
          plan enrollee, except for applicable co-payments and 
          deductibles.

          In addition to recovering disputed payments for providers, 
          DMHC reports that through February 2011, the PCU levied 
          more than $650,000 in fines to health plans which it 
          determined had improperly paid claims in violation of state 
          law.  DMHC reports that the fines include two fines 
          totaling $350,000 against Health Net in 2005 for making 
          incorrect payments to emergency doctors and contracted 
          health care facilities, $200,000 against Blue Cross for 
          failing to properly pay interest and penalties on late 
          claims, and $50,000 against Blue Shield for making payments 
          directly to patients instead of providers.  

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          According to DMHC, from January 1, 2011, to the present, 
          the PCU has received 2,652 provider complaints, prosecuted 
          10 matters involving claims payment violations, and 
          assessed $531,000 in penalties.  In addition, DMHC has 
          received 31 applications to participate in the IDRP to 
          resolve provider grievances.  According to DMHC, the PCU 
          generally does not review complaints related to whether a 
          health plan is appropriately paying usual and customary 
          charges for services provided by providers who are not 
          under contract with health plans, but DMHC is in the 
          process of amending the existing payment criteria to 
          facilitate such review.  

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

          According to the Senate Appropriations Committee:

                          Fiscal Impact (in thousands)

           Major Provisions                2011-12     2012-13    
           2013-14   Fund
           DMHC enforcement                             up to the low 
          hundreds of              Special*
                                   thousands of dollars annually
          *Managed Care Fund

           SUPPORT  :   (Verified  8/29/11)

          American College of Emergency Physicians, California 
          Chapter
          California Academy of Family Physicians
          California Association of Marriage and Family Therapists
          California Medical Association
          California Psychiatric Association
          California Psychological Association
          California Society of Anesthesiologists
          California Society of Dermatology and Dermatologic Surgery

           ARGUMENTS IN SUPPORT  :    The California Chapter of the 
          American College of Emergency Physicians (cal/acep), writes 
          that AB 1059 would ensure that when a health plan is found 
          to have underpaid physicians, the physician is paid the 

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          correct amount without incurring even more costs due to 
          having to resubmit claims.  CAL/ACEP states that, in some 
          instances when DMHC has taken an enforcement action against 
          a health plan for underpaying physicians, DMHC requires the 
          physician to resubmit their claim to obtain full payment.  
          For emergency physicians, the amount of underpayment is 
          often less than $100 and the cost to find the old claim and 
          resubmit is more than the amount of underpayment, forcing 
          the physician to lose even more money when seeking 
          restitution.  CAL/ACEP argues that enforcement actions by 
          DMHC often allow the offending health plan to profit on 
          their illegal act, and cites a 2004 case in which DMHC 
          found that Health Net underpaid physicians between $6 
          million and $7 million over a 9 month period.  In that 
          case, the penalty issued was a $250,000 fine and $750,000 
          in restitution to physicians, which allowed Health Net to 
          profit by their illegal activities by more than $5 million. 
           

          The California Psychological Association writes that, 
          despite previous efforts to address widespread payment 
          abuses by HMOs, there are still patterns of late payments, 
          non-payments, and consistent denials of payment after 
          providing prior authorization for the service.  The 
          California Society of Anesthesiologists states that, 
          although anesthesiologists provide services that are 
          mandated by law in emergency situations, some health plans 
          try to underpay for essential services.  The California 
          Academy of Family Physicians states that many primary care 
          offices are operating on razor thin fiscal margins and 
          financial gaming of those who have lawfully provided 
          valuable health care services is a dangerous gamble with 
          California's already depleted primary care workforce.  The 
          California Medical Association writes that this bill 
          ensures physicians who are victims of HMOs breaking the law 
          are made whole, deters future violations of the law by 
          ensuring sufficient penalties are assessed, and protects 
          the health care delivery system and patient care by 
          ensuring physicians are financially capable of providing 
          service for patients.  The California Psychiatric 
          Association states that this bill's provisions are common 
          sense and clarify existing law with respect to fairness in 
          managed care organizations dealings with physician 
          providers.

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           ASSEMBLY FLOOR  :  49-26, 06/02/11
          AYES:  Alejo, Allen, Ammiano, Atkins, Beall, Block, 
            Blumenfield, Bonilla, Bradford, Brownley, Buchanan, 
            Butler, Charles Calderon, Campos, Carter, Cedillo, 
            Chesbro, Davis, Dickinson, Eng, Feuer, Fong, Fuentes, 
            Furutani, Gatto, Gordon, Halderman, Hayashi, Roger 
            Hern�ndez, Hill, Hueso, Huffman, Lara, Bonnie Lowenthal, 
            Ma, Mendoza, Mitchell, Monning, Pan, Perea, V. Manuel 
            P�rez, Portantino, Skinner, Solorio, Swanson, Wieckowski, 
            Williams, Yamada, John A. P�rez
          NOES:  Achadjian, Bill Berryhill, Conway, Cook, Donnelly, 
            Fletcher, Beth Gaines, Garrick, Grove, Hagman, Harkey, 
            Huber, Jeffries, Jones, Knight, Logue, Mansoor, Miller, 
            Morrell, Nielsen, Norby, Olsen, Silva, Smyth, Valadao, 
            Wagner
          NO VOTE RECORDED:  Galgiani, Gorell, Hall, Nestande, Torres


          CTW:nl  8/29/11   Senate Floor Analyses 

                         SUPPORT/OPPOSITION:  SEE ABOVE

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