BILL ANALYSIS                                                                                                                                                                                                    Ó



                                                                  AB 1761
                                                                  Page  1

          Date of Hearing:  March 27, 2012

                            ASSEMBLY COMMITTEE ON HEALTH
                              William W. Monning, Chair
             AB 1761 (John A. Pérez) - As Introduced:  February 17, 2012
           
          SUBJECT  :  California Health Benefit Exchange.

           SUMMARY  :  Gives the Department of Managed Health Care (DMHC) and 
          the Commissioner of the California Department of Insurance (CDI) 
          enforcement authority over licensees (and solicitors) who hold 
          themselves out as representing or providing services on behalf 
          of the California Health Benefit Exchange (Exchange) without a 
          valid agreement.  Makes holding oneself out as representing, 
          constituting, or otherwise providing services on behalf of the 
          Exchange without a valid agreement unfair competition.  
          Specifically,  this bill  :  

          1)Prohibits an individual or entity from holding himself, 
            herself, or itself out as representing, constituting, or 
            otherwise providing services on behalf of the Exchange unless 
            that individual or entity has a valid agreement with the 
            Exchange to engage in those activities.  Extends the violation 
            to any individual or entity that aids or abets another 
            individual or entity in violation of this prohibition.

          2)Makes it an unfair business practice for a solicitor, 
            solicitor firm, or a health care service plan to hold himself, 
            herself, or itself out as representing, constituting, or 
            otherwise providing services on behalf of the Exchange unless 
            the solicitor or solicitor firm has a valid agreement with the 
            Exchange to engage in those activities.

          3)Adds to the list of practices defined as unfair methods of 
            competition and unfair and deceptive acts or practices in the 
            business of insurance holding oneself out as representing, 
            constituting, or otherwise providing services on behalf of the 
            Exchange without a valid agreement to engage in those 
            activities.

           EXISTING LAW  :  

          1)Establishes DMHC to regulate health plans and CDI to regulate 
            health insurance.









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          2)Establishes the Exchange pursuant to the federal Patient 
            Protection and Affordable Care Act (ACA) which authorizes 
            states to establish health benefit exchanges for individuals 
            and small business to compare health insurance products and 
            purchase policies from among four categories:  Bronze, Silver, 
            Gold, and Platinum, and for some purchasers, obtain subsidies 
            and tax credits.

          3)Authorizes the DMHC Director to suspend or revoke a health 
            plan's license or issue disciplinary action.  Provides for 
            civil penalties not to exceed $2,500 per violation, and 
            criminal penalties no more than $10,000 or one year 
            imprisonment or jail, or both. 

          4)Makes any person who engages in any unfair method of 
            competition or any unfair or deceptive act or practice, as 
            defined, liable to the state for a civil penalty to be fixed 
            by the commissioner of the CDI, not to exceed $5,000 for each 
            act, or, if the act or practice was willful, a civil penalty 
            not to exceed $10,000 for each act. 
           FISCAL EFFECT  :  This bill has not yet been analyzed by a fiscal 
          committee.

           COMMENTS  :

           1)PURPOSE OF THIS BILL  .  According to the author, this bill 
            helps prevent deceptive marketing of the Exchange by not 
            allowing individuals or entities to represent themselves as 
            acting on behalf of the Exchange unless authorized to do so by 
            the Exchange.  The author indicates that in January 2014, the 
            Exchange will be operational and need a marketing strategy to 
            create awareness for its products.  The ACA requires that 
            exchanges develop "navigators" who will help reach and educate 
            potential enrollees.  However, the navigators' specific roles 
            and responsibilities have yet to be defined by the state.  The 
            author adds that the Health and Safety Code defines "unfair 
            business practices" for entities regulated by DMHC, the 
            Insurance Code defines "unfair methods of competition and 
            unfair deceptive acts or practices in the business of 
            insurance" for entities regulated by CDI, and the Government 
            Code establishes the duties of the Exchange, but none of these 
            code sections address the issue of deceptive marketing of the 
            Exchange.

           2)BACKGROUND  .  On March 23, 2010, President Obama signed the ACA 








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            (Public Law 111-148), as amended by the Health Care and 
            Education Reconciliation Act of 2010 (Public Law 111-152).  
            Among other provisions, the new law makes statutory changes 
            affecting the regulation of and payment for certain types of 
            private health insurance.  Each state is required to establish 
            an American Health Benefit Exchange and a Small Business 
            Health Options Program Exchange by 2014 for individuals and 
            small employers with 50 to 100 employees; after 2017, states 
            have the option of opening the small business exchange to 
            employers with more than 100 employees.  States can opt to 
            provide a single exchange for individuals and small employers. 
             Groups of states can form regional exchanges or states can 
            form more than one in-state exchange, but the exchanges must 
            serve a geographically distinct area.  While the individual 
            and small-group markets will not be replaced by the exchanges, 
            the same market rules will apply inside and outside the 
            exchanges.  Premium subsidies can be used only for plans 
            purchased through the exchanges.  The Exchange was established 
            in 2010 as an independent public entity within state 
            government with a five-member board appointed by the Governor 
            and Legislature.

           3)SUPPORT  .  Health Access California supports this bill because 
            at the moment that AB 1602 (John A. Pérez), Chapter 655, 
            Statutes of 2010, was enacted to create the official Exchange 
            to begin implementation of the ACA, there have been misleading 
            websites put up by agents and brokers that appear to be the 
            official website of the Exchange.  According to Health Access 
            California this bill takes the simple step of saying that only 
            an individual or entity with a valid, in-force agreement with 
            the Exchange can hold themselves out as acting on behalf of 
            the Exchange.  

           4)RELATED LEGISLATION  .  SB 1313 (Lieu), among other provisions, 
            prohibits a person from making any statement to a person that 
            is known, or should have been known, to be a misrepresentation 
            regarding the requirements of the ACA.  SB 1313 is pending in 
            the Senate.

           5)PREVIOUS LEGISLATION  .  

             a)   AB 1602 establishes the Exchange as an independent 
               public entity to purchase health insurance on behalf of 
               Californians, including those with incomes of between 100% 
               and 400% of the federal poverty level, and small 








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               businesses.  Clarifies the powers and duties of the board 
               governing the Exchange relative to the administration of 
               the Exchange, determining eligibility and enrollment in the 
               Exchange, and arranging for coverage under qualified 
               carriers.  

             b)   SB 900 (Alquist), Chapter 659, Statues of 2010 
               establishes the Exchange and requires the Exchange to be 
               governed by a five-member board, as specified.

           REGISTERED SUPPORT / OPPOSITION  :  

           Support 
           
          California Association of Health Underwriters
          Health Access California
          Insurance Brokers and Agents of the West
          National Association of Insurance and Financial Advisors of 
          California


           Opposition 
           
          None on file.
           
          Analysis Prepared by  :    Teri Boughton / HEALTH / (916) 319-2097