BILL ANALYSIS                                                                                                                                                                                                    �



                                                                            



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                                    THIRD READING


          Bill No:  SB 1046
          Author:   Beall (D)
          Amended:  4/8/14
          Vote:     21

           
           SENATE HEALTH COMMITTEE  :  9-0, 4/2/14
          AYES:  Hernandez, Anderson, Beall, De Le�n, DeSaulnier, Evans,  
            Monning, Nielsen, Wolk

           SENATE APPROPRIATIONS COMMITTEE  :  Senate Rule 28.8


            SUBJECT  :    Insurance:  mental illness:  developmental  
                      disabilities:  coverage:  penalties

           SOURCE  :     Department of Insurance


           DIGEST  :    This bill authorizes the Commissioner of the  
          Department of Insurance (CDI) to assess administrative penalties  
          for any violations of the Mental Health Parity Act (MHPA),  
          including any rules or orders adopted or issued based on  
          violations of those provisions.  This bill also gives the  
          Commissioner authority to assess a penalty for each patient  
          harmed by a violation of the above provisions, as a separate and  
          distinct violation.  Imposes penalties of up to $2,500 for each  
          violation, or for an ongoing and continuous violation, $2,500  
          per day for as long as the violation continues.

          ANALYSIS  :    

          Existing law:
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           1. Establishes CDI to regulate health insurance pursuant to the  
             Insurance Code and the Department of Managed Health Care  
             (DMHC) to regulate health plans under the Knox-Keene Act.

           2. Requires, under MHPA, health plans and health insurers to  
             provide coverage for the diagnosis and medically necessary  
             treatment of severe mental illnesses of a person of any age,  
             and of serious emotional disturbances of a child, as  
             specified, under the same terms and conditions applied to  
             other medical conditions, as specified.

           3. Requires, under MHPA, maximum lifetime benefits, copayments  
             and coinsurance, and individual and family deductibles to be  
             applied equally to all benefits under the plan or policy.

           4. Defines, under MHPA, "severe mental illnesses" to include:

              A.    Schizophrenia;
              B.    Schizoaffective disorder;
              C.    Bipolar disorder (manic-depressive illness);
              D.    Major depressive disorders;
              E.    Panic disorder;
              F.    Obsessive-compulsive disorder;
              G.    Pervasive developmental disorder (PDD) or autism;
              H.    Anorexia nervosa; and
              I.    Bulimia nervosa.

           5. Requires health plans and insurers to also provide coverage  
             for behavioral health treatment (BHT) for PDD or autism no  
             later than July 1, 2012, and requires the coverage to be  
             provided in the same manner and subject to the same  
             requirements as provided in #2-4 above.

           6. Requires health plans and insurers to maintain an adequate  
             network that includes qualified autism service providers who  
             supervise and employ qualified autism service professionals  
             or paraprofessionals who provide and administer BHT. 

           7. Establishes Kaiser Small Group HMO as California's Essential  
             Health Benefits (EHB) benchmark plan, which includes MHPA,  
             treatment for behavioral health, treatment for PDD or autism,  
             the federal Mental Health Parity and Addiction Equity Act of  
             2008 and all rules, regulations and guidance issued pursuant  

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             to the Affordable Care Act, as mandated coverage required of  
             non-grandfathered individual and small group health plan  
             contracts and insurance policies.

          This bill:

          1. Authorizes the Commissioner to assess administrative  
             penalties against insurers for violations of MHPA and  
             requirements associated with BHT for PDD or autism.

          2. Makes any person who violates the laws described in #1 above,  
             or who violates any rules or orders adopted or issued  
             pursuant to laws governing health insurers, as specified,  
             based on a violation of the laws described in #1 above,  
             liable for a penalty not to exceed $2,500 for each violation  
             or, for a violation that is ongoing and continuous, not to  
             exceed $2,500 for each day that the violation continues.  

          3. Makes each patient harmed by a violation of MHPA and  
             requirements associated with BHT for PDD, as specified, a  
             separate and distinct violation subject to the penalties set  
             forth in this bill.

          4. Makes the remedies provided by this bill and by other  
             sections of the Insurance Code not exclusive, and authorizes  
             that the remedies be sought and employed in any combination  
             to enforce the laws governing health insurers, as specified.

          5. Authorizes the Commissioner to determine penalties imposed  
             pursuant to these provisions, as specified. 

           Prior Legislation
           
          SB 126 (Steinberg, Chapter 680, Statutes of 2013) extends, until  
          January 1, 2017, the sunset date of an existing state health  
          benefit mandate that requires health plans and health insurance  
          policies to cover BHT for PDD or autism and requires plans and  
          insurers to maintain adequate networks of service providers.

          AB 1453 (Monning, Chapter 854, Statutes of 2012) and SB 951  
          (Hernandez, Chapter 866, Statutes of 2012) established  
          California's EHBs.

          SB 946 (Steinberg, Chapter 650, Statutes of 2012) requires  

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          health plans and health insurance policies to cover BHT for PDD  
          or autism, requires plans and insurers to maintain adequate  
          networks of autism service providers, established an Autism Task  
          Force in DMHC, and sunsets the bill's autism mandate provisions  
          on July 1, 2014.  

          SB 1283 (Steinberg, 2010) would have established guidelines to  
          expedite the appeals process for grievances that are filed with  
          DMHC and imposed fines on health plans that did not comply, as  
          specified.  The bill was vetoed by Governor Schwarzenegger. 

          AB 88 (Thomson, Chapter 534, Statutes of 1999) requires a health  
          care service plan contract or disability insurance policy to  
          provide coverage for severe mental illness, and for the serious  
          emotional disturbances of a child under the same terms and  
          conditions as applied to other medical conditions.

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

           SUPPORT  :   (Verified  4/30/14)

          Department of Insurance (source)
          American Association for Marriage and Family Therapy 
          Autism Speaks 
          California Association for Behavior Analysis 
          California Chapter American College of Emergency Physicians 
          California Council of Community Mental Health Agencies 
          California Mental Health Planning Council 
          California Psychiatric Association 
          California Psychological Association 
          Children Now 
          Mental Health America of California
          National Alliance on Mental Illness 
          Southern California Psychiatric Society 
          The Children's Partnership 

           OPPOSITION  :    (Verified  4/30/14)

          Association of California Life and Health Insurance Companies

           ARGUMENTS IN SUPPORT  :    CDI sponsors this bill to give CDI  
          equal treatment with DMHC enforcement penalties for  
          non-compliance with the MHPA.  California's MHPA requires that  

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          all comprehensive health insurance policies provide coverage for  
          the diagnosis and medically necessary treatment of severe mental  
          illness of a person of any age, and of serious emotional  
          disturbance of a child under the same terms and conditions  
          applied to other medical conditions.  CDI promulgated emergency  
          regulations which prohibit specified conditions or limitations  
          on coverage of therapies when determined to be medically  
          necessary to ensure compliance with MHPA.  CDI is currently  
          working on finalizing permanent mental health parity  
          regulations.  In addition, California's EHB law incorporates the  
          requirements from both the federal and state mental health  
          parity laws.  Currently DMHC regulations allow for a violation  
          that is ongoing and continuous to be subject to a civil penalty  
          for each day that a violation continues.  Additionally, each  
          enrollee harmed constitutes a separate and distinct violation  
          subject to civil penalty.  Under the Insurance Code every  
          violation is an unfair insurance practice, which cannot be  
          multiplied by the number of days the violation occurs.  This  
          bill rectifies the penalty disparity between CDI and DMHC.  The  
          California Association for Behavior Analysis believes CDI should  
          be given penalty authority in line with the penalty authority of  
          DMHC to enhance current enforcement efforts of the MHPA to  
          ensure consumers have access to mental health services in  
          compliance with the law.

           ARGUMENTS IN OPPOSITION  :    The Association of California Life  
          and Health Insurance Companies (ACLHIC) writes that currently  
          CDI has the authority to evaluate the policies and procedures of  
          health insurers to ensure compliance with all requirements of  
          the law, including those services that fall within the mental  
          health parity statutes.  As such, CDI already has very broad  
          authority under the Insurance Code to impose civil penalties of  
          up to $5,000 per act and/or $10,000 for a willful act or  
          practice against any person who engages in any unfair method of  
          competition or any unfair or deceptive act.  ACLHIC adds that  
          this bill, as drafted, is not identical or even consistent with  
          the referenced DMHC civil penalty and the two enforcement  
          actions are, for numerous reasons, distinctively different.     
           

          JL:k  4/30/14   Senate Floor Analyses 

                           SUPPORT/OPPOSITION:  SEE ABOVE


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