BILL ANALYSIS                                                                                                                                                                                                    �



                                                                      



           ------------------------------------------------------------ 
          |SENATE RULES COMMITTEE            |                   SB 866|
          |Office of Senate Floor Analyses   |                         |
          |1020 N Street, Suite 524          |                         |
          |(916) 651-1520         Fax: (916) |                         |
          |327-4478                          |                         |
           ------------------------------------------------------------ 
           
                                         
                                 THIRD READING


          Bill No:  SB 866
          Author:   Hernandez (D)
          Amended:  5/31/11
          Vote:     21

           
           SENATE HEALTH COMMITTEE  :  7-0, 4/13/11
          AYES:  Hernandez, Strickland, Alquist, Anderson, De Le�n, 
            DeSaulnier, Rubio
          NO VOTE RECORDED:  Blakeslee, Wolk

           SENATE APPROPRIATIONS COMMITTEE  :  6-2, 5/26/11
          AYES:  Kehoe, Alquist, Lieu, Pavley, Price, Steinberg
          NOES:  Walters, Runner
          NO VOTE RECORDED:  Emmerson


           SUBJECT  :    Health care coverage:  prescription drugs

           SOURCE  :     Author


           DIGEST  :    This bill directs the Department of Managed 
          Health Care and the Department of Insurance, on or before 
          January 1, 2013, to develop a standardized prior 
          authorization form for prescription drug benefits, as 
          specified, and requires "prescribing providers," as 
          defined, to use, and health care service plans and health 
          insurers to accept, the standardized form when requiring 
          prior authorization for prescription drug benefits.  

           ANALYSIS  :    

                                                           CONTINUED





                                                                SB 866
                                                                Page 
          2

          Existing law:

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

          2. Imposes various requirements and restrictions on certain 
             procedures, commonly referred to as utilization review, 
             that apply to every health plan and insurer that 
             prospectively, retrospectively, or concurrently reviews 
             and approves, modifies, delays, or denies, based on 
             medical necessity, requests by providers prior to, 
             retrospectively, or concurrent with, the provision of 
             health care services to enrollees or insureds, as 
             specified.  

          3. Imposes various requirements and restrictions on health 
             plans and insurers, including, among other things, a 
             prohibition on health plans and insurers that provide 
             prescription drug benefits from excluding or limiting 
             coverage for a drug on the basis that the drug is 
             prescribed for a use that is different from the use for 
             which the drug has been approved for marketing by the 
             federal Food and Drug Administration. 

          4. Requires health plans and insurers to respond to 
             requests for authorization within five business days for 
             non-urgent medically necessary health care services, as 
             specified, or within 72 hours for situations when the 
             enrollee or insured's condition is such that he or she 
             faces an imminent and serious threat to his or her 
             health, as specified.

          5. Requires health plans and insurers to communicate 
             decisions to approve, modify or deny requests within 24 
             hours of the decision to the provider, with certain 
             exceptions.  

          6. Requires health plans and insurers to communicate 
             decisions resulting in the denial, delay or modification 
             of all or part of the request to the enrollee or insured 
             within two business days.

                                                           CONTINUED





                                                                SB 866
                                                                Page 
          3


          7. Requires health plans that provide prescription drug 
             benefits to maintain an expeditious process by which 
             prescribing providers, as described, may obtain 
             authorization for a medically necessary nonformulary 
             prescription drug, according to certain procedures.

          This bill:

          1. Directs DMHC and CDI to jointly develop a standardized 
             prior authorization form for prescription drug benefits 
             on or before January 1, 2013, which every prescribing 
             provider is required to use to request prior 
             authorization for coverage of prescription drug 
             benefits.

          2. Defines "prescribing provider" as a provider authorized 
             to write a prescription to treat a medical condition of 
             an enrollee, as currently defined in existing law.

          3. Requires health plans and insurers that provide 
             prescription drug benefits to accept the standardized 
             form when requiring prior authorization for prescription 
             drug benefits.

          4. Specifies that the form shall not exceed two pages, be 
             made electronically available by the departments and 
             health plans and insurers, and may be electronically 
             submitted from the prescribing provider to the health 
             plan or insurer.

          5. Requires DMHC and CDI to develop the form with input 
             from interested parties, as specified.

          6. Requires DMHC and CDI, in developing the form, to 
             consider existing prior authorization forms established 
             by the federal Centers for Medicare and Medicaid and the 
             state Department of Health Care Services, and national 
             standards for electronic prior authorization.  If the 
             health plan or insurer fails to use or accept the prior 
             authorization form, or fails to respond within two 
             business days upon receipt of a request from a 
             prescribing provider who has submitted a prior 
             authorization form, the prior authorization request 

                                                           CONTINUED





                                                                SB 866
                                                                Page 
          4

             shall be deemed granted.

          7. Exempts Medi-Cal managed care plans from the 
             two-business day requirement.

          8. Provides an exemption for a physician or physician group 
             that has been delegated the financial risk for 
             prescription drugs by a health plan and does not use a 
             prior authorization process within the group.

           Background  

          Prior authorization is a common cost-containment and 
          utilization review method used by health plans, insurers, 
          and some public coverage programs.  The practice of prior 
          authorization, also called prior approval or 
          preauthorization, requires a prescriber to obtain 
          permission from the health plan or insurer to prescribe a 
          medication before prescribing it.  

          Health plans and insurers routinely require physicians to 
          fill out prior authorization forms when the provider 
          prescribes a medicine or treatment not covered by the plan 
          or insurer's formulary.  Each plan or insurer has their own 
          prior authorization form, and some plans and insurers may 
          have multiple forms depending on the type of drug 
          requested.

          Prior authorization is intended to curb abuse and diversion 
          of controlled substances, and has been shown to be 
          effective in controlling prescription drug costs.  
          Medications that commonly require prior authorization 
          include:

          1. Brand name medications that have a generic available; 
          2. Expensive medications;
          3. Drugs not usually covered by the insurance company, but 
             said to be medically necessary by the doctor;
          4. Drugs usually covered but prescribed at a higher dosage;
          5. Drugs used for cosmetic reasons; and
          6. Drugs prescribed to treat a non-life threatening medical 
             condition. 

           FISCAL EFFECT  :    Appropriation:  No   Fiscal Com.:  Yes   

                                                           CONTINUED





                                                                SB 866
                                                                Page 
          5

          Local:  Yes

          According to the Senate Appropriations Committee:

                          Fiscal Impact (in thousands)

           Major Provisions     2011-12     2012-13      2013-14     Fund  

          DMHC regulations   up to $75 up to $150           
          $0Special*

          Increased complaints         potentially in the hundreds of 
          thousands                    Special*
          to DMHC            of dollars in first year; unknown 
          ongoing

          Increased prescriptions      potentially in the hundreds of 
          thousands                    General/**
          approved           to millions of dollars annually 
          commen-Federal/
                             cing FY 2012-13                
          Special/Other

          * Managed Care Fund
          **Healthy Families costs shared 35 percent General Fund, 65 
            percent federal funds; CalPERS costs shared 55 percent 
            General Fund, 45 percent special and other funds
           
           SUPPORT  :   (Verified  5/27/11)

          Alliance for Patient Access
          American Academy of Private Physicians
          American Cancer Society
          Association of Northern California Oncologists
          BayBio
          BIOCOM
          California Academy of Family Physicians
          California Association of Health Plans
          California Association of Physician Groups
          California Healthcare Institute
          California Medical Association
          California NeuroAlliance
          Los Angeles County Medical Association 
          Medical Oncology Association of Southern California, Inc.

                                                           CONTINUED





                                                                SB 866
                                                                Page 
          6

          National Council of Asian Pacific Islander Physicians
          Neuropathy Action Foundation
          Orange County Medical Association 
          Osteopathic Physicians and Surgeons of California
          Pharmaceutical Research and Manufacturers of America
          Power of Pain Foundation
          US Pain Foundation

           OPPOSITION  :    (Verified  5/27/11)

          California Association of Health Plans (unless amended)

           ARGUMENTS IN SUPPORT  :    The California Medical Association 
          writes in support, stating that preauthorization policies 
          lead to costly bureaucratic hassles that take time from 
          patient care.  The Medical Oncology Association of Southern 
          California, Inc. asserts that the prior authorization 
          process is currently highly complex, lacks transparency, 
          and the criteria and processes vary significantly among 
          health plans.  Furthermore, these different requirements 
          create logistical complexity for providers, as well as 
          adding duplicative overhead and staff time.  The American 
          Academy of Private Physicians concurs, stating that 
          providers need to be able to get back to the work of 
          patient care and should not be spending needless time 
          trying to figure out which health plan has what protocol 
          and what form.

          The Alliance for Patient Access supports this bill, citing 
          that health plans and insurers have great incentive to 
          limit a physician's treatment options by using prior 
          authorization as a way to cut costs.  Writing in 
          concurrence, the Power of Pain Foundation states that they 
          receive calls regularly from Californians stating that, in 
          the course of the prior authorization process, they are 
          forced to go days and/or weeks before they obtain/continue 
          to get treatments deemed necessary by their provider, and 
          that they are forced to go through the prior authorization 
          process multiple times a year for the same medication for 
          the same condition.

           ARGUMENTS IN OPPOSITION  :    The Californian Association of 
          Health Plans (CAHP) opposes the bill unless amended, citing 
          that health plans use drug specific prior authorization 

                                                           CONTINUED





                                                                SB 866
                                                                Page 
          7

          forms because each drug is unique in its requirements for 
          diagnosis, limitations, existing diseases, treatment 
          failures and other clinically relevant information, and 
          that applying a standardized prior authorization form could 
          create even more administrative burdens if the form does 
          not ask the appropriate questions which will subsequently 
          lead to follow-up calls and faxes.  CAHP further objects to 
          the provision in the bill that deems approval of a prior 
          authorization request if a plan or insurer does not respond 
          to a prior authorization request within 48 hours or if the 
          plan or insurer fails to use the standard form, and raises 
          concerns that the bill does not address situations where 
          the provider fails to respond to a request for additional 
          information or fails to use the standardized form.  In 
          addition, CAHP notes that the implementation date for 
          plans, insurers and providers is unclear.  
           

          CTW:mw  5/31/11   Senate Floor Analyses 

                         SUPPORT/OPPOSITION:  SEE ABOVE

                                ****  END  ****
          





















                                                           CONTINUED