BILL ANALYSIS                                                                                                                                                                                                    �







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        |Hearing Date:April 7, 2014         |Bill No:SB                         |
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                      SENATE COMMITTEE ON BUSINESS, PROFESSIONS 
                               AND ECONOMIC DEVELOPMENT
                              Senator Ted W. Lieu, Chair
                                           

                        Bill No:        SB 1256Author:Mitchell
                   As Introduced:     February 21, 2014 Fiscal: Yes

        
        SUBJECT:  Medical services: credit
        
        SUMMARY:  Prohibits  all  healing arts licensees or an employee or agent  
        of that licensee from arranging for or establishing credit extended by  
        a third party without first providing a written notice and treatment  
        plan to a patient and would prohibit that arrangement or establishment  
        of credit with regard to a patient who has been administered or is  
        under the influence of general anesthesia, conscious sedation, or  
        nitrous oxide.  It also prohibits  all  healing arts licensees or an  
        employee or agent of that licensee from charging treatment not yet  
        rendered or costs not yet incurred to an open-end credit extended by a  
        third party without providing the patient with information regarding  
        the treatment and services, and requires all licensees to refund any  
        payment received for treatment that has not been incurred within 15  
        business days upon the patient's request.

        Existing law:
        
        1) Defines "open-end credit" as the credit extended by a creditor  
           under a plan in which the creditor reasonably contemplates repeated  
           transactions.  (Business and Professions Code (BPC) � 654.3(i)(2))

        2) Specifies that the creditor may impose a finance charge from time  
           to time on an outstanding unpaid balance and the amount of credit  
           that may be extended to the debtor during the term of the plan is  
           generally made available to the extent that any outstanding balance  
           is repaid.  (Civil Code (CC) � 1812.405)

        3) Specifies that the term patient includes, but is not limited to,  
           the patient's parent or other legal representative.  (BPC � 654.3  





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           (i)(3))

        4) Prohibits a dentist or employee or agent of a dentist from charging  
           treatment not yet rendered, or costs not yet incurred, to an  
           open-end credit extended by a third party without first providing  
           the patient with specified information regarding the treatments and  
           services to be rendered and ensuring the patient's receipt of the  
           treatment plan.  (BPC � 654.3 (a))

        5) Requires a dentist, within 15 business days of a patient's request,  
           to refund to the lender any payment received through credit  
           extended by a third party that is arranged for or established in a  
           dental office, for treatment that has not been rendered or costs  
           that have not been incurred.  (BPC � 654.3 (b))

        6) Requires a dentist or an employee or agent of a dentist to provide  
           the patient with a written notice on one page in at least 14 type  
           font and to get a signature from the patient in order to arrange  
           for or establish credit extended by a third party.  (BPC � 654.3  
           (c))

        7) Prohibits  a dentist or employee or agent of a dentist from  
           arranging for or establishing credit extended by a third party for  
           a patient with whom the dentist or employee or agent of the dentist  
           communicates with in a language other than English unless the  
           written notice information is also provided in that language.  (BPC  
           � 654.3 (e))

        8) Prohibits a dentist, employee or agent of that dentist from  
           establishing credit that is extended by a third party for a patient  
           who has been administered or is under the influence of general  
           anesthesia, conscious sedation or nitrous oxide.  (BPC 654.3 (f))

        9) Establishes that a person who willfully violates these provisions  
           is subject to civil liability.  (BPC � 654.3(g))

        This bill:

        1) Defines a "licensee" as an individual, firm partnership,  
           association, corporation, limited liability company or cooperative  
           association.

        2) Defines "licensee's" office as an office of a licensee in solo  
           practice or an office in which services or goods are provided by  
           the licensee or by employees in that office, or by independent  
           contractors in that office.





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        3) Defines "open-end credit" as credit extended by a creditor under a  
           plan in which the creditor reasonably contemplates repeated  
           transactions.

        4) Allows the creditor to impose a finance charge from time to time on  
           an outstanding unpaid balance, up to any limit set by the creditor.

        5) Specifies that a "patient" includes, but is not limited to, the  
           patient's parent or legal representative.

        6) Prohibits a healing arts licensee, or an employee or agent of that  
           licensee, from arranging for or establishing credit extended by a  
           third party for a patient without first providing a written notice  
           and a written treatment plan.

        7) Prohibits the arrangement or establishment of credit with regard to  
           a patient who has been administered or is under the influence of  
           general anesthesia, conscious sedation or nitrous oxide.

        8) Prohibits a healing arts licensee, or employee or agent of a  
           licensee, from charging treatment not yet rendered or costs not yet  
           incurred to an open-end credit extended by a third party that is  
           arranged for or established in the licensee's office without first  
           providing the patient with specified information regarding the  
           treatment and services to be rendered and ensuring the patient's  
           receipt of the treatment plan.

        9) Requires a healing arts licensee to refund to the lender any  
           payment received for treatment that has not been rendered, or costs  
           that have not been incurred within 15 business days upon the  
           patient's request.

        10)Provides that a person who willfully violates these provisions is  
           subject to civil liability.

        FISCAL EFFECT:  Unknown. This bill has been keyed "fiscal" by  
        Legislative Counsel.

        COMMENTS:
        
        1. Purpose.  This bill is sponsored by the  Consumer Federation of  
           California  .  According to the Author, SB 1256 extends the current  
           protections that patients receive in a dental office to other areas  
           of the medical field.  The Author believes that medical credit  
           cards, extended through third party lenders, but solicited by  





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           medical providers, pose a significant risk to consumers who may not  
           fully understand the arrangements that are being made for them by  
           their provider or provider's office.  The interest rates for these  
           credit cards can range between 24 and 28 percent and may include  
           significant penalty fees charged retroactively on the entire cost  
           of the procedure.  The significant risks created by deferred  
           interest credit cards in connection to medical services make it  
           essential that consumers fully understand the arrangements they  
           make with their medical providers. 

        2. Background.  

            a)    Medical Credit Card Popularity.  Medical credit cards have  
              increased in popularity over the past decade.  U.S. financial  
              institutions have partnered with health care providers to offer  
              medical credit cards to people without health insurance or those  
              who require services not covered by their insurance including  
              dental care, vision, hearing aids, cosmetic procedures and  
              veterinary care.  According to Craig Conway, a research  
              professor with the University of Houston Law Center in Texas,  
              U.S. citizens spend about $294 billion annually on out-of-pocket  
              medical expenses, a quarter of which they charge to standard  
              credit cards.  However, an estimated 79 million people have  
              trouble paying those expenses and, as a result, health care  
              providers struggle to collect money owed to them (University of  
              Houston Law Center, Health Law Perspective, November 2009).  The  
              American Medical Association and the American Dental Association  
              have no formal policy on medical credit cards, but some  
              practitioners refuse to use them, saying they threaten to  
              exploit the traditional relationship between provider and  
              patient.  

            b)    Medical Credit Card Companies.  Consumer Reports indicates  
              that health care credit card providers such as Capital One  
              Healthcare Finance, Chase Health Advance and Citi Health Card  
              charge interest rates ranging from 24 to 28 percent with credit  
              limits as high as 40 thousand dollars (Overdose of Debt,  
              Consumer Reports, July 2008).  Financial institutions such as  
              General Electric, U.S. Bancorp and Citigroup are also medical  
              creditors.  According to a November 2007 Business Week article  
              entitled, Fresh Pain for the Uninsured, General Electric owns  
              Care Credit, and according to Care Credit's website, it has 6  
              million customers and is marketed to dentists, plastic surgeons  
              and some hospitals.  U.S. Bank, a U.S. Bancorp unit, finances  
              about $2 million in patient debt per month through a  
              medical-benefit firm, charging most customers annual interest of  





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              13.5 percent and as much as 24 percent on late bills.

            c)    Other States.  The inception of medical credit cards began  
              in a few states, including Texas and North Carolina, and spread  
              quickly across the country.  However, in recent years, several  
              states have issued warnings to consumers about using medical  
              credit cards.  Some states have sued medical credit card  
              companies for deceptive business practices. 

               i)       In August of 2009, Minnesota's Attorney General, Lori  
                 Swanson, issued a consumer alert to warn patients that a trip  
                 to a clinic looking to "boost its bottom line" could result  
                 in a barrage of high-pressure sales pitches.  Attorney  
                 General Swanson also issued a consumer alert warning for  
                 residents to be aware of abusive practices involving medical  
                 credit cards and has investigated several providers. She  
                 remarked, "[T]his is the health care version of sub-prime  
                 predatory mortgage lending.  Enrolling people in exploding  
                 interest credit cards, not explaining the terms of those  
                 credit cards, [and] jeopardizing people's credit histories."   
                 In 2010, Attorney General Swanson sued two chiropractic  
                 clinics, charging that, among other things, they signed  
                 patients up for credit cards without their knowledge and  
                 charged them thousands of dollars for services not yet  
                 provided (The Washington Post, Be Skeptical of Health-Care  
                 Credit Cards, August 2010; Canadian Medical Association  
                 Journal, 2010; The Office of the Attorney General, Minnesota,  
                 Lori Swanson, Health Care Credit Cards, available at  
                 http://www.ag.state.mn.us/Brochures/pubHealthCareCreditCards.p 
                 df).

               ii)         In August of 2010, New York's Attorney General,  
                 Andrew Cuomo, announced an expansion of an investigation into  
                 the "predatory lending practices" of medical centers pushing  
                 the cards.  The investigation, launched after hundreds of  
                 complaints from consumers, had already found that some health  
                 care practices were using "fast-talking sales pitches to  
                 pressure and deceive" consumers, including seniors and  
                 vulnerable patients.  Specifically, the state accused medical  
                 card provider CareCredit of having deceptive terms and  
                 pushing the cards on unwary patients.  As a result, as part  
                 of the Consumer Financial Protection Bureau lawsuit,  
                 CareCredit was ordered to issue nearly 2 million dollars in  
                 refunds to consumers in the state of New York (The Wall  
                 Street Journal, Market Watch, Medical Credit Cards Come with  
                 a Catch, September 2013; Canadian Medical Association  





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                 Journal, 2010).

               iii)        Similarly, in 2013, the Consumer Financial  
                 Protection Bureau ordered GE Capital Retail Bank and its  
                 subsidiary, CareCredit, to refund up to 34.1 million dollars  
                 to potentially more than 1 million consumers, including the  
                 aforementioned consumers in the state of New York, who were  
                 victims of deceptive credit card enrollment tactics.  At  
                 doctors' and dentists' offices around the country, consumers  
                 were signed up for CareCredit credit cards they thought were  
                 interest free, but were actually accruing interest that  
                 kicked in if the full balance was not paid at the end of a  
                 promotional period (Consumer Financial Protection Bureau,  
                 CFPB Orders GE CareCredit to Refund $34.1 Million for  
                 Deceptive Health-Care Credit Card Enrollment, December 2013).

               iv)         In 2010, Aspen Dental, reached a settlement with  
                 Pennsylvania authorities over claims that it had failed to  
                 tell patients that missing a payment would mean the rate  
                 would rise from zero to nearly 30 percent (The New York  
                 Times, Patients Mired in Costly Credit From Doctors, October  
                 2013). 

               v)       In 2013, the Ohio Attorney General sued the operators  
                 of several hearing aid clinics, claiming that they misled  
                 customers about using medical credit cards to pay for  
                 batteries and warranties (The New York Times, Patients Mired  
                 in Costly Credit From Doctors, October 2013).

        3. Arguments in Support.  The  Consumer Federation of California  
           (Sponsor)  supports the bill and writes, "Medical credit cards  
           provide a financing option that helps patients pay for treatments  
           or procedures that are not otherwise covered by their medical  
           insurance?However, in some instances, patients who thought they  
           were signing up for a payment plan directly with their provider  
           later discover that they have signed credit applications and may  
           have eventually paid up-front for treatments they have not yet  
           received?patients, primarily elderly, low-income or limited  
           English-speaking, who are offered a credit card when they are most  
           vulnerable? may not understand that the financing option they have  
           been recommended is actually a credit card or loan extended through  
           a third party.  SB 1256 is not intended to prohibit medical  
           providers from helping to arrange credit cards or loans for their  
           patients, but aims to set forth basic standards governing these  
           credit card arrangements and provide basic consumer protections."






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        4. Prior Legislation.   AB 171  (Jones, Chapter 418, 2009) established  
           procedures for dentists to follow when arranging a medical credit  
           card, extended through a third party lender, to a patient.

            SB 1633  (Kuehl, 2008) would have prohibited a person providing  
           dental services, or an employee or agent of that person, from  
           charging to a line of credit or other extension of credit, or  
           accept payment from loan funds for services that the patient,  
           client, or customer has not yet received.  (  Status  : Governor  
           Schwarzenegger summarily vetoed SB 1633 because of the budget  
           crisis.)
        
         
        NOTE  :  Double-referral to Judiciary Committee (second).
        

        SUPPORT AND OPPOSITION:
        
         Support:  

        Consumer Federation of California (Sponsor)

         Opposition:  

        None received as of April 1, 2014



        Consultant:Le Ondra Clark, Ph.D.