BILL ANALYSIS                                                                                                                                                                                                    �



                                                                  SB 1256
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          Date of Hearing:   June 24, 2014

              ASSEMBLY COMMITTEE ON BUSINESS, PROFESSIONS AND CONSUMER  
                                     PROTECTION
                               Susan A. Bonilla, Chair
                   SB 1256 (Mitchell) - As Amended:  June 11, 2014

           SENATE VOTE  :   36-0
           
          SUBJECT  :   Medical services: credit.

           SUMMARY  :  Extends existing consumer protections regarding lines  
          of credit for dental services to all types of medical or healing  
          arts services by requiring a licensee to provide a patient with  
          a treatment plan, a disclosure form, and information about  
          third-party payment coverage, and also establishes language and  
          competency requirements.  Specifically,  this bill  :   

          1)Prohibits a licensee from charging treatment or costs to an  
            open-end credit or loan, that is extended by a third party and  
            that is arranged for, or established in, that licensee's  
            office, before the date upon which the treatment is rendered  
            or costs are incurred, without first providing the patient a  
            list of the treatment and services to be rendered, the  
            estimated costs of the treatment and services, and which  
            treatment and services are being charged in advance of  
            rendering or incurring of costs, and ensuring that the patient  
            has received the treatment plan, as specified.

          2)Requires a licensee, 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, that licensee's office for treatment that has  
            not been rendered or costs that have not been incurred.

          3)Prohibits a 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 written  
            notice, as specified, on one page in at least 14-point type,  
            and obtaining a signature from the patient. 

          4)Requires a licensee to provide a patient with a written  
            treatment plan prior to arranging for or establishing credit  
            extended by a third party.  The treatment plan shall include  
            each anticipated service to be provided and the estimated cost  








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            of each service. 

          5)States that if a patient is covered by a private or government  
            medical benefit plan or medical insurance from which the  
            licensee takes assignment of benefits, the treatment plan  
            shall indicate the patient's private or government-estimated  
            share of cost for each service. If the licensee does not take  
            assignment of benefits from a patient's medical benefit plan  
            or insurance, the treatment plan shall indicate that the  
            treatment may or may not be covered by a patient's medical  
            benefit or insurance plan, and that the patient has the right  
            to confirm medical benefit or insurance information from the  
            patient's plan, insurer, or employer before beginning  
            treatment.

          6)Prohibits a licensee, or an employee or agent of that  
            licensee, from arranging for or establishing credit extended  
            by a third party for a patient with whom the licensee, or an  
            employee or agent of that licensee, communicates primarily in  
            a language other than English that is one of the Medi-Cal  
            threshold languages, unless the written notice information is  
            also provided in that language.

          7)Prohibits a licensee, or an employee or agent of that  
            licensee, from arranging for or 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.

          8)Authorizes a patient who suffers any damage as a result of  
            anything prohibited by this bill to seek relief through the  
            methods authorized under the Consumer Legal Remedies Act, as  
            specified.  

          9)States that the rights, remedies, and penalties established by  
            this bill are cumulative, and shall not supersede the rights,  
            remedies, or penalties established under other laws.

          10)Defines the terms "licensee," "licensee's office," and  
            "patient".

          11)Defines the term "open-end credit" means credit extended by a  
            creditor under a plan in which the creditor reasonably  
            contemplates repeated transactions, the creditor may impose a  
            finance charge from time to time on an outstanding unpaid  








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            balance, and the amount of credit that may be extended to the  
            debtor during the term of the plan, up to any limit set by the  
            creditor, is generally made available to the extent that any  
            outstanding balance is repaid.

          12)States that no reimbursement is required by this bill because  
            the only costs that may be incurred by a local agency or  
            school district will be incurred because this bill creates a  
            new crime or infraction, eliminates a crime or infraction, or  
            changes the penalty for a crime or infraction, or changes the  
            definition of a crime.

           EXISTING LAW  :

          1)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 (CIV) Section  
            1812.405)

          2)Authorizes, under the Consumer Legal Remedies Act, any  
            consumer who suffers any damage as a result of the use or  
            employment by any person of a method, act, or practice  
            declared to be unlawful, as specified, to bring an action  
            against that person to recover or obtain any of the following:

             a)   Actual damages, but in no case shall the total award of  
               damages in a class action be less than one thousand dollars  
               ($1,000);

             b)   An order enjoining the methods, acts, or practices;

             c)   Restitution of property;

             d)   Punitive damages; or,

             e)   Any other relief that the court deems proper.  (CIV  
               1780)

          3)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  








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            ensuring the patient's receipt of the treatment plan.   
            (Business and Professions Code (BPC) Section 654.3(a))

          4)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))

          5)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))

          6)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))

          7)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))

           FISCAL EFFECT  :   Unknown

           COMMENTS  :   

           1)Purpose of this bill  .  This bill extends existing consumer  
            protections regarding lines of credit for dental services to  
            all types of licensed healing arts services.  SB 1256 also  
            requires a licensee to provide a patient with a treatment  
            plan, a disclosure form, information about third-party payment  
            coverage, and establishes language and competency  
            requirements.  This bill will help consumers make better  
            informed financial decisions.  This bill is enforceable by a  
            private right of action and is sponsored by the Consumer  
            Federation of California.   

           2)Author's statement  .  According to the author's office,  








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            "Patients, primarily elderly, low-income or limited  
            English-speaking, who thought they had signed a payment plan  
            with their provider, later come to realize they have signed up  
            for credit cards or loans they cannot afford.  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.

            "SB 1256 simply extends the current protections that patients  
            receive in a dental office to other areas of the medical  
            field." 

           3)Medical credit cards  .  According to a December 10, 2013  
            article in the New York Times, medical credit cards are often  
            much more costly to patients than they realize, and have  
            attracted the attention of the Consumer Financial Protection  
            Bureau (Bureau):  


               Richard Cordray, the Bureau's director, said the  
               agency had received hundreds of complaints about the  
               [medical credit] card and found that many patients who  
               were offered it thought they were signing up for an  
               interest-free payment plan. But, in fact, they were  
               applying for a deferred-interest credit card that had  
               a no-interest promotional period of up to two years.  
               Interest accrued during the promotion at an annual  
               rate of 26.99 percent - much higher than a typical  
               bank credit card, he said. If the balance wasn't paid  
               by the end of the promotional period, the patient  
               became liable for the interest, resulting in "a very  
               expensive loan," he said. 


               Other similar credit cards are available, but  
               CareCredit [a division of GE Capital Retail Bank] is  
               one of the largest in the industry, the bureau said.  
               It is offered by about 175,000 doctors, dentists,  
               vision care and veterinary offices across the country.  
               There are about four million active CareCredit  
               cardholders. 


               Providers like the cards because they get paid up  








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               front, but the cards can get unwitting patients into  
               debt at a time when they may not be fully focused on  
               financial details. "They're not on guard financially,"  
               he said. "Their focus is on getting better." 


               Many patients did not receive copies of the credit  
               agreement, he said, but relied on oral explanations  
               from office staff members who often received little  
               training. 


            This bill would require licensees who offer such cards or  
            loans from third party providers to provide written  
            information to patients on the nature of the payment  
            providers, repayment, and billing.  

           4)Disclosure statement  . The bill requires the following  
            disclosure to be provided to the patient on one page, in at  
            least 14-point font:  

               Credit for Medical Services

               The attached application and information is for a  
               credit card/line of credit or loan to help you finance  
               your medical treatment. You should know that:

               You are applying for a ____ credit card/line of credit  
               or a ____ loan for $____.

               You do not have to apply for the credit card/line of  
               credit or loan. You may pay your medical provider for  
               treatment in another manner.

               This credit card/line of credit or loan is not a  
               payment plan with the provider's office; it is credit  
               with [name of company issuing the credit card/line of  
               credit or loan]. Your medical provider does not work  
               for this company.

               Before applying for this credit card/line of credit or  
               loan, you have the right to a written treatment plan  
               from your medical provider that includes the  
               anticipated treatment to be provided and the estimated  
               costs of each service.








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               If you are approved for a credit card/line of credit,  
               your medical provider can only charge treatment and  
               laboratory costs to that credit card/line of credit  
               when you get the treatment or the medical provider  
               incurs costs unless your medical provider has first  
               given you a list of treatments that you are paying for  
               in advance and the cost for each treatment or service.

               You have the right to receive a credit to your credit  
               card/line of credit or loan account refunded for any  
               costs charged to the credit card/line of credit or  
               loan for treatment that has not been rendered or costs  
               that your medical provider has not incurred. Your  
               medical provider must refund the amount of the charges  
               to the lender within 15 business days of your request,  
               after which the lender will credit your account.

               Please read carefully the terms and conditions of this  
               credit card/line of credit or loan, including any  
               promotional offers.

               You may be required to pay interest rates on the  
               amount charged to the credit card/line of credit or  
               the amount of the loan. If you miss a payment or do  
               not pay on time, you may have to pay a penalty on the  
               entire cost of your procedure and/or a higher interest  
               rate.

               You may use this credit card/line of credit for  
               payments toward subsequent medical services.

               If you do not pay the money that you owe the company  
               that provides you with a credit card/line of credit or  
               loan, your missed payments can appear on your credit  
               report and could hurt your credit rating. You could  
               also be sued.

               [Patient's Signature]

           5)Remedies  .  The provisions of this bill may be enforced through  
            the Consumer Legal Remedies Act, which declares, in part, that  
            a consumer that suffers damage as a result of unlawful  
            business practices may bring a suit to recover actual damages,  
            an order for the offender to stop the unlawful act,  








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            restitution, punitive damages, and any other relief the court  
            deems proper.    
             
           6)Author's amendments  .  The author would like to change  
            references from "medical provider" to "health care provider"  
            in the disclosure statement to better characterize the breadth  
            of licensees affected by this bill.  

            The author would also like to add Asm. Skinner as a co-author.  
             
                
            7)Arguments in support  .  The Consumer Federation of California  
            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, including some  
            vision, hearing and cosmetic care.  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 even paid  
            up-front for treatments they have not yet received.  The  
            interest rate on these cards, if promotional, may start out at  
            0% with a credit limit of up to $40,000.  However, after a  
            late payment, or at the end of the promotional period,  
            interest rates can climb to between 24% and 28% with  
            additional penalties and retroactive fees on the entire cost  
            of the care received."  
             
             "While medical credit cards closely resemble other credit  
            cards, there is one very important difference: medical credit  
            cards are solicited and offered to the consumer by their  
            medical provider, not by banks or creditors.  In most  
            instances, a patient who has built a relationship with their  
            medical provider may consider them an advisor when it comes to  
            their medical care.  Patients, primarily elderly, low-income  
            or limited English-speaking, who are offered a credit card  
            when they are most vulnerable - such as when they are in pain  
            or when a provider has recommended a treatment they cannot  
            afford - 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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            8)Previous legislation  .  AB 171 (Jones) Chapter 418, Statutes of  
            2009, established requirements governing the arrangement of  
            credit cards and loans for dental services and prohibits a  
            dentist, or an employee or agent of a dentist, from charging  
            to a third party line of credit for services that have not  
            been rendered, or costs that have not been incurred, unless  
            the patient receives a list of treatment and services to be  
            rendered, including the estimated costs, and a written  
            treatment plan, as specified.  

           REGISTERED SUPPORT / OPPOSITION  :

           Support 
           
          The Consumer Federation of California (sponsor)
          The California Immigrant Policy Center 
          Board of Chiropractic Examiners
           
            Opposition 
           
          None on file

           Analysis Prepared by  :    Sarah Huchel / B.,P. & C.P. / (916)  
          319-3301