BILL ANALYSIS                                                                                                                                                                                                    



                                                          AB 55
                                                          Page  1

Date of Hearing: April 20, 1999

                ASSEMBLY COMMITTEE ON JUDICIARY 
                    Sheila James Kuehl, Chair
           AB 55 (Migden) - As Amended:  April 15, 1999
  
SUBJECT  : HMOs:  INDEPENDENT MEDICAL REVIEW, LIABILITY AND  
ADMISSIBILITY

 KEY ISSUES  :

1)SHOULD HMOs BE LEGALLY RESPONSIBLE FOR THE HARM THEY CAUSE  
  WHEN FAILING TO EXERCISE ORDINARY CARE IN PROVIDING OR DENYING  
  HEALTH CARE?

2)Should a NEW independent medical review system for unresolved  
  PATIENT complaints against HMOs be established in California?

3)Should THIS AND ALL OTHER INDEPENDENT MEDICAL REVIEW BILLS BE  
  AMENDED, CONSISTENT WITH THE COMMITTEE'S POSITION LAST  
  SESSION, TO ENSURE THAT ALL ASPECTS of the independent medical  
  review system contemplated in this bill ARe INadmissible in  
  subsequent JUDICIAL PROCEEDINGS?

  SUMMARY  :  Holds health maintenance organizations (HMOs) legally  
responsible for the harm they cause when failing to exercise  
ordinary care in providing or denying health care, permits the  
admissibility of independent review decisions in court  
proceedings under the normal rules of evidence, expedites HMO  
and DOC review of patient complaints, and establishes an  
independent medical review system for specified unresolved  
patient complaints against HMOs.   Specifically,  this bill  :   

1)Establishes an Independent Medical Review System, commencing  
  January 1, 2001, that requires health plans to provide  
  enrollees the opportunity to seek an independent medical  
  review whenever health care services have been denied or  
  terminated or otherwise limited by a plan or one of its  
  contracting providers based in whole or in part on a finding  
  that the proposed health care services are not medically  
  necessary or medically appropriate.

2)Authorizes an enrollee to apply for Independent Review if one  
  of the following conditions is met:









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   a)   the enrollee has received a provider recommendation  
     indicating that the disputed service is medically necessary  
     or medically appropriate;

   b)   the enrollee has received the disputed service on an  
     urgent care or emergency basis from a provider who  
     determined it was medically necessary or medically  
     appropriate; or 

   c)   in the absence of a) or b), the enrollee has been seen  
     by an in-plan provider for the medical condition for which  
     the enrollee seeks independent review.

3)Provides that independent reviews be conducted by expert  
  medical organizations independent of health plans and  
  certified by a nonprofit accrediting organization, pursuant to  
  specified conflict of interest provisions. 

4)Requires independent review decisions to determine whether the  
  disputed service is or was medically necessary or appropriate  
  based on specified practice guidelines, relevant medical or  
  scientific evidence, or generally accepted standards of  
  medical practice. 

5)Permits the admissibility of independent review decisions in  
  judicial cases under normal rules of evidence.   

6)Provides that a health plan shall have a duty of ordinary care  
  to provide medically appropriate health care service to its  
  members, subscribers, or enrollees where the health care  
  service is a benefit generally provided under the plan.  The  
  bill would make a health care service plan or managed care  
  entity liable for any and all harm resulting from the failure  
  to exercise ordinary care in the provision, approval, or  
  denial of health care services.

  EXISTING LAW  :

1)Requires every health plan to maintain a grievance system  
  under which enrollees may submit their grievances to the plan.  
   An enrollee may submit an unresolved grievance to DOC after  
  completing the health plan grievance process or after  
  participating in the process for 60 days.  Health plans must  
  address emergency grievances within five days.  (Health and  
  Safety Code sections 1368 and 1368.01.)








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2)Regulates, pursuant to the federal Employee Retirement Income  
  Security Act (ERISA), employee benefit plans, including health  
  plans.  ERISA has been interpreted to bar state common law  
  claims for compensatory and punitive damages against an  
  employer-provided health plan for alleged improper handling of  
  benefit decisions, including improper denial of treatment  
  under the plan.  (See  Pilot Life Ins. Co. v. Dedeaux   (1987)  
  481 U.S. 41.)

3)Provides that only relevant evidence is admissible, and that  
  all relevant evidence is admissible unless the court excludes  
  it, after a finding that its probative value is substantially  
  outweighed by the probability that its admission will  
  necessitate undue consumption of time or create a substantial  
  danger of undue prejudice, of confusing the issues, or of  
  misleading the jury.  (Evidence Code sections 350, 351, and  
  352.)

4)Limits testimony of witnesses who are not experts to what may  
  be rationally based on the his or her perception and what may  
  be helpful for a clear understanding of the testimony.   
  (Evidence Code Section 800.)

5)Limits testimony of expert witnesses, permitting only  
  testimony that is both: 

   a)   "Related to a subject that is sufficiently beyond the  
     common experience that the opinion of the expert would  
     assist the trier of fact;" and 

   b)   "Based on matter (including special knowledge, skill,  
     experience, training, and education) perceived by or  
     personally known to the witness or made known to him at or  
     before the hearing, whether or not admissible, that is of a  
     type that reasonably may be relied upon by an expert in  
     forming an opinion upon the subject to which his testimony  
     relates, unless an expert is precluded by law from using  
     such matter as a basis for his opinion."  (Evidence Code  
     section 801.)

  FISCAL EFFECT  :  Unknown

  COMMENTS  :  This bill, one of several independent medical review  
bills moving through the Legislature this year, laudably seeks  








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to address the growing belief held by many Californians that  
they are being denied medical care simply to maximize corporate  
profits.  The bill passed the Assembly Health Committee by a  
vote of 9-5 on April 13, 1999.  It is very similar to AB 1621  
(Thomson), which is also scheduled to be heard by this Committee  
April 20, 1999, and which also passed the Assembly Health  
Committee on April 13, 1999 (in that instance by a bipartisan  
vote of 11-0).  Because this bill received an extensive analysis  
and hearing in the Health Committee, this analysis will focus on  
the principal issues in this bill which are within the  
jurisdiction of the Judiciary Committee. 

  Brief Comparison Between AB 55 and AB 1621  :  Regarding the  
development of a new independent medical review system in  
California, AB 55 and AB 1621 are very similar, and, in the view  
of patient  protection groups, are both generally promising  
legislative efforts.  Before turning to the principal legal  
issue raised by both bills, that of the admissibility of the  
independent review process in later court cases, a brief  
comparison of their key differences may prove helpful. 

Whereas AB 55 contains provisions holding HMOs liable for the  
harm they cause when making treatment decisions, AB 1621 does  
not contain these liability provisions on the ground that other  
bills (like AB 55) are addressing this patient protection issue.

In addition, both bills are "silent" on the issue of admitting  
aspects of the independent medical review process in subsequent  
judicial proceedings.  As such, the traditional rules of  
evidence would appear to apply to both bills - a contrary  
approach to the position adopted by this Committee when  
considering this identical issue last year.  At that time, the  
Committee voted consistently in support of the proposition that  
no aspects of the proposed independent medical review programs  
should be admissible in any subsequent judicial proceeding.   
(See fuller discussion below.) 

The primary differences between AB 55 and AB 1621 on the other  
issues pertaining to the independent review process are  
relatively minor, and include:   

 1. AB 55 has a slightly different approach to  
   conflict-of-interest protections than AB 1621, reflecting the  
   different nature of the review participants in the two bills;
 2. AB 1621 designates those individuals providing the  








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   independent medical review of the treatment decision as  
   "providers of second opinions," whereas AB 55 refers to  
   "independent reviewers," reflecting the more formal and  
   larger make-up of the review panel created in this  
   legislation; and 
 3. AB 1621 removes the $250,000 cap on administrative fines  
   that may be imposed by DOC on health plans that knowingly and  
   repeatedly fail to act promptly and reasonably to resolve  
   grievances.

  Author's Statement  :  In support of the bill, the author  
notes the growing fear across the country that too often  
medical decisions are being made by insurance company  
accountants instead of doctors and patients; that too  
often, "managed" care is mismanaged, dangerous care,  
dictated more by money than by medicine.   As the author  
notes, HMOs now dominate the health insurance market in  
California.  Many of these companies have become large  
for-profit enterprises, forcing not-for-profit HMOs to  
increasingly emphasize cost-cutting as a top priority.  The  
author therefore notes the following:

     "AB 55 . . . in my view goes to the heart of restoring  
     consumer confidence in our health care system.  I've  
     introduced AB 55 to require a fully independent,  
     outside review when HMOs deny care, and to give  
     consumers access to courts that we who work in this  
     Capitol building already enjoy. . . .AB 55 rectifies  
     the current situation where patients and their doctors  
     who believe needed care has been denied can be left  
     hanging while the dispute resolution process drags on  
     indefinitely.  While there may be occasions when the  
     treatment a patient wants may not be appropriate or  
     necessary, I believe when HMOs deny a patient care,  
     those patients should have the right to an independent  
     look from someone concerned with that patient's  
     health, not preoccupied with the company's bottom  
     line. 

     AB 55 also makes HMOs liable in court for decisions  
     that harm the health of their patients. In doing so,  
     we reaffirm a basic principle of our democracy - that  
     there are three branches of government, not two - and  
     that California citizens deserve access to each one -  
      including  the courts. . . .It has been suggested that  








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     granting Californians the right to take HMOs to court  
     will be too costly.  AB 55 recognizes that attempts to  
     deny citizens the right to step through the doors of  
     their own government ultimately impose a far greater  
     cost."

  Historical Backdrop:  Governor Wilson's 1998 Managed Care Task  
Force Recommendations  :  Last year, Governor Wilson's Managed  
Health Care Improvement Task Force issued a series of  
recommendations to reform managed health care in California.   
One of these recommendations specifically pertained to  
"Independent Third Party Review."  That recommendation called  
for the following: 

"The state entity for regulation of managed care should be  
directed to establish and implement by January 1, 2000,  an  
independent third-party review  process  that would provide  
consumers and health plans with an unbiased, expert-based review  
of grievances pertaining to delays, denials, or curtailment of  
care based on medical necessity, appropriateness, and all  
'experimental-investigational treatments.'"  (Emphasis added.) 
   
The various independent review bills introduced in the  
Legislature this year, including this one and 
AB 1621 (Thomson) (scheduled to be heard contemporaneously with  
this bill), directly seek to implement this Task Force  
recommendation. 
   
  The Federal Backdrop  :  As California policymakers consider  
which, if any, HMO reforms have the most merit, Congress and the  
President are also struggling with what combination of reforms  
will most improve HMO practices nationwide.  For example,  
legislation now pending in Congress, called the Patient Bill of  
Rights, would grant a broad array of new rights for enrollees in  
managed care plans, including the right for HMO patients to go  
to court when injured by the denial of needed medical care.   
President Clinton has strongly endorsed this measure, as have  
hundreds of organizations representing millions of patients,  
doctors, nurses, persons with disabilities or chronic illnesses,  
and many others. 
   
  Recent Poll Results in California  :  When considering public  
support for the types of HMO reform proposals currently before  
the Committee, the Committee may wish to note the results of a  
1999 statewide survey conducted by Fairbank, Maslin, Maullin &  








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Associates on this issue, which found that voters in California  
are overwhelmingly dissatisfied with their HMOs, and feel very  
strongly that they should have the right to sue them for  
inappropriate conduct.

When asked particularly if Californians should have the basic  
right to sue HMOs if the HMO unreasonably delays or denies a  
claim, this survey reports that 85 percent felt they should have  
this right, with nearly two-thirds feeling strongly about it.   
Support for the right to sue apparently crosses party and  
ideological lines, as nearly equal numbers of Democrats (89  
percent), Independents (86 percent), Republicans (86 percent),  
and conservatives (86 percent) surveyed stated they believe they  
should have this legal right.  (Survey Summary on file in  
Committee.)

  Background  :  As noted above, the Assembly Health Committee  
strongly supported the health care reform policies in this bill  
leading to the creation of a new independent medical review  
system in California.  The principal issue before this  
Committee, therefore, pertains to the bill's provisions holding  
HMOs liable for their treatment decisions, and whether all  
aspects of the independent review process should be inadmissible  
in subsequent court proceedings.  Some brief background follows  
to assist the Committee in grappling with these complex legal  
issues.

  The Liability Approach of this Bill  :  This bill would make tort  
remedies available for all health care service plans or managed  
care patients and enrollees whose provision of benefits and  
services are unreasonably or wrongfully delayed or denied.   In  
amendments contemplated to track, verbatim, the liability  
provisions being amended into SB 21 by Senator Figueroa, this  
bill would provide that a health care service plan or managed  
care entity is:
 
1)Legally responsible to patients to ensure that the health care  
  provider, rather than the plan or managed care entity, shall  
  be in charge of patient care for services rendered on or after  
  January 1, 2000.
2)Subject to a duty of ordinary care to provide medically  
  appropriate health care service to its members, subscribers,  
  or enrollees where the health care service is a benefit  
  provided under the plan.
3)Liable for any and all harm resulting from the failure to  








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  exercise ordinary care in the provision or denial of health  
  care services.
4)Not, by reason of this measure, defined as a health care  
  provider under any provision of law, including provisions of  
  the Medical Injury Compensation Reform Act (MICRA).
5)Prohibited from seeking contractual or equitable indemnity  
  from a provider for its liability incurred under provisions a)  
  and b), above.
6)Not subject to any new or additional liability for the sole  
  medical negligence, as defined, of a treating health care  
  provider. 

  ERISA Preemption  :  Federal law, the Employee Retirement Income  
Security Act  (ERISA), regulates employee benefit plans,  
including health plans.  ERISA has been interpreted to generally  
bar state common law claims for compensatory and punitive  
damages against an employer-provided health plan for alleged  
improper handling of benefit decisions, including improper  
denial of treatment under the plan.  (See  Pilot Life Ins. Co. v.  
Dedeaux  (1987) 481 U.S. 41.) 
   
An estimated 75 to 80 percent of all health insurance enrollees  
are covered by ERISA plans and are therefore subject to this  
preemption.  These enrollees' only remedy is the recovery of  
contract damages.  The other 20 to 25 percent of the enrollee  
population, those covered by a public employee or government  
sponsored (e.g. Medi-Cal) plan and those who bought individual  
policies, are free to pursue tort damages for the improper  
provision of benefits or "failure to treat." 

Since 1987, there has been a great deal of debate in the legal  
world as to whether a state statute seeking to impose civil  
liability on a health plan can ever survive ERISA preemption  
after the U.S. Supreme Court's seemingly unequivocal holding in  
  Pilot Life  .  Those arguing that  Pilot Life  prevents such state  
efforts cite the fact that many federal circuit court cases, and  
various state appellate cases issued after  Pilot Life  , have  
broadly construed the case to expressly provide that state  
statutory regulation of health claims practices are flatly  
preempted by ERISA's enforcement provision.  (See, for example,  
  Kanne v. Connecticut General Life Ins. Co.  (9th Cir. 1988) 867  
F. 2d 489;  Commercial Life Ins. Co. v Superior Court (Juliano)   
(1988) 47 Cal. 3d. 473; and  Greany v. Western Farm Bureau Life  
Ins. Co.  (9th Cir. 1992) 973 F. 2d 812.) 









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Proponents of state avenues of control in this area,  
notwithstanding ERISA, argue that "[a] slavish desire to fulfill  
  Pilot Life's  mandate to protect ERISA plans at all costs reads  
far too much into the . . . decision and [have] extrapolated out  
of it conclusions that were never expressly stated in it."   
(Letter of Support for 
AB 55 by the Consumer Attorneys of California on file in the  
Committee.)  In support of this position, they note that the  
Supreme Court's discussion in  Pilot Life  regarding exclusive  
ERISA preemption was dicta (not relevant to the outcome or  
holdings of that case).  They also argue that preemption  
advocates in this area paint the ERISA bar under  Pilot Life  far  
too broadly, since they fail to note the distinction between  
state efforts to regulate the processing of patient claims via  
the health plan versus the insurer.  According to this argument:

     There is no question that the  Pilot Life  decision  
     contemplates the application of ERISA's civil  
     enforcement scheme as the exclusive means of  
     regulating the manner in which a plan processes  
     claims, even if it does so through the purchase of an  
     insurance policy.  But -- and this is a very important  
     but -- the Supreme Court nowhere states that a state  
     regulatory scheme . . . is ineffective with respect to  
     regulating the insurer, even as to the manner in which  
     the insurer processes claims. 

Whether or not the particular approach taken in this  
legislation, holding health plans liable for the harm they cause  
their enrollees for the failure to exercise ordinary care, will  
survive ERISA preemption must await resolution by the courts.  

  ARGUMENTS IN SUPPORT  :  The California School Employees  
Association, California Psychiatric Association, California  
Teachers Association, and the Union of American Physicians &  
Dentists support this bill because it allows enrollees to appeal  
unresolved grievances after 30 days instead of 60, provides for  
an independent review system when health services are denied,  
and imposes accountability and liability on health plans.   
Supporters argue that experience in other states that have  
independent review systems has shown that the mere existence of  
such a process seems to act as a policing mechanism that  
increases the reasonableness of health plans in reviewing the  
medical necessity of decisions.  They also believe that this  
bill will help ensure that health care treatment decisions are  








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driven by physicians and not health plans.       
  
  The Consumer Attorneys of California (CAOC) also supports this  
bill if it is amended to ensure that no aspect of the  
independent review process established under the bill is  
admissible in any subsequent legal proceeding.  (See fuller  
discussion of this issue below.)  CAOC supports giving enrollees  
the right to sue HMOs.  With regard to independent review, CAOC  
wants to ensure that consumers need not exhaust the review  
process before having standing to sue.  CAOC also supports the  
bill's recent amendments that ensure a broad definition of  
medical necessity that focuses on the needs of the particular  
patient.  It also favors the recent amendments taken in the  
Health Committee which allow both Medi-Cal and Medicare  
beneficiaries access to the independent review system and also  
eliminate application fees for appeals, arguing that such fees  
may discourage legitimate appeals.  CAOC also argues against  
withholding privileged HMO information from patients requesting  
documents on appeal.  

Neighbor to Neighbor (N2N), a non-profit health access  
organization, supports AB 55, stating:

     Currently, everyone who gets health care coverage  
     individually or through a government or church  
     employer receives the full protection of state laws,  
     while those who get their coverage through group  
     employer contracts do not.  AB 55 extends the full  
     protection of state laws to every person in this state  
     regardless of how they get their health coverage.  In  
     so doing, AB 55 would create a strong deterrent for  
     health care service plans and health insurers (HMOs)  
     to interfere with health providers' medical judgment.  
     . . .HMOs require a strong financial deterrent to  
     counterbalance the overwhelmingly strong financial  
     incentive they currently have to second-guess the  
     judgment of physicians and other health providers.  
     This legislation, as amended, would protect patients  
     and health care providers by making HMOs take full  
     responsibility for the consequences of wrongfully  
     denied care.
  
ARGUMENTS IN OPPOSITION  :  The Association for California Tort  
Reform opposes provisions in this bill which increase health  
plan liability.  Blue Cross opposes the extension of tort  








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liability to health plans, and Kaiser continues to favor  
independent review over liability lawsuits.  With regard to  
independent review, Blue Cross recommends that the results of  
external review should be admissible in any subsequent legal  
proceeding. 

In addition to concerns about the liability provisions, the  
California Association of Health Plans seeks amendments  
regarding independent review to ensure that decisions are  
admissible, that reviewers meet specified qualifications, that a  
government entity selects the independent reviewers, and that  
the review process is conducted in a timely manner.  The  
California Physician Groups Council seeks amendments to remove  
the liability provisions and to fine tune the independent review  
sections.  The California Chamber of Commerce argues that this  
bill will result in defensive medical practices that will lead  
to increased costs and unnecessary treatment, and as costs go up  
the number of uninsured will go up as well. 

The Association of California Life and Health Insurance  
Companies writes that it opposes the bill unless substantial  
amendments are taken.  It especially objects to the bill's  
"attempt to redefine HMO coverage as 'the business of insurance'  
to avoid ERISA preemption."  It also notes that "the bill would  
directly impact employee benefit plans . . . and make them  
subject to enterprise liability.  Therefore, this bill ropes in  
other lines of insurance and employee benefit plans unrelated to  
managed care, thus potentially expanding their exposure to  
lawsuits, without any commensurate legal benefit to the patients  
the bill purports to help."
  
  The Health Insurance Association of America (HIAA) writes in  
strong opposition to the bill's liability provisions, stating  
that as a result of expanded liability, "businesses will be  
forced to pay higher costs.  By dramatically increasing the cost  
of health care, California will increase the number of uninsured  
persons in this state. . . .The costs to California employers  
and employees for the expansion of medical malpractice liability  
is estimated to be between $1.02 billion and $2 billion  
annually."  Additionally HIAA argues that "the administrative,  
compliance and 'defensive medicine' costs associated with such  
increased liability measures are conservatively estimated at  
4-5% [increase in health care costs], with potential increases  
                                                                        as high as 12%."









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 ISSUE:  SHOULD THIS AND ALL OTHER INDEPENDENT MEDICAL REVIEW  
BILLS BE AMENDED, CONSISTENT WITH THE COMMITTEE'S POSITION LAST  
SESSION, TO ENSURE THAT ALL ASPECTS OF THE INDEPENDENT MEDICAL  
REVIEW SYSTEM CONTEMPLATED IN THIS BILL ARE INADMISSIBLE IN  
SUBSEQUENT JUDICIAL PROCEEDINGS  ?  Last session, several bills,  
including 
AB 1667 (Migden), SB 1504 (Rosenthal) and SB 1653 (Johnston),  
attempted to establish independent medical review systems.  When  
this Committee heard the various independent review bills last  
year, the issue arose as to whether any aspects of the  
independent review process should be admissible in subsequent  
court proceedings.  The Committee consistently voted against  
permitting any such information to be admitted in court  
proceedings.  Because both of the independent review proposals  
before the Committee this year are silent on this issue, thereby  
permitting admissibility of independent review decisions under  
normal evidentiary rules, the admissibility issue is once again  
squarely presented to the Committee.  Following are the  
principal arguments pro and con on this issue submitted to the  
Committee this year.

  The Argument For Admissibility  :  The California Medical  
Association (CMA) wrote the Committee to argue strongly that the  
"second opinion" approach taken in AB 1621, whereby a single  
doctor provides a second opinion about the need for  
patient-requested treatment, is sufficiently informal and  
reliable as to support admissibility of the process in  
subsequent court proceedings.  Although its statement on this  
issue was expressly directed to why such "second opinions"  
should be admissible under the normal rules of evidence, as  
opposed to this bill's independent review "panel" approach, it  
raises several points which reflect the key arguments in support  
of admitting this type of independent review information.   

Among other things, CMA states:

     We believe that the adversarial judicial process and  
     the existing rules of evidence for relevance and  
     expert witness testimony have been more than adequate  
     in dealing with the admissibility of a medical opinion  
     and the weight that a trier of fact would give such  
     evidence. . . .As you know, California Evidence Code  
     Section 351 provides that, except as otherwise  
     provided by statute, all relevant evidence is  
     admissible.  Further, the court has the discretion to  








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     exclude evidence if its probative value is  
     substantially outweighed by the probability that its  
     admission will . . . create substantial danger of  
     undue prejudice, of confusing the issues, or of  
     misleading the jury (Evidence Code Sec. 352). 

     Currently, if a patient in a PPO or other non-HMO  
     health insurance plan seeks and obtains a second  
     medical opinion, unless the court determines  
     otherwise, everything related to that visit to the  
     second opinion provider that is relevant will be  
     admitted in any subsequent proceeding.  This begs the  
     question as to why the rules of evidence are different  
     if the second opinion is sought from an HMO enrollee?   
     If the patient is in a PPO, that evidence is  
     admissible in subsequent legal actions.  If that  
     patent is an HMO enrollee, CAOC would have that  
     evidence be inadmissible. 

Kaiser Permanente also wrote the Committee to argue  
strongly against taking the approach of last session and  
making any aspect of the independent medical review process  
inadmissible in subsequent court proceedings.  Kaiser  
wrote:

     [We believe] that the decisions of the independent  
     medical review organization should be admissible for  
     all relevant purposes not inconsistent with existing  
     provisions of the Evidence Code, and that no special  
     provisions regarding the admissibility of such  
     decisions should be enacted.  Because the decision of  
     the independent medical review organization would be  
     binding only on the plan, it would be patently unfair  
     to limit evidence in a subsequent appeal regarding the  
     organization's decision. . . .Of the more than 20  
     states that have enacted independent medical review  
     statutes, no state that we are aware of has imposed  
     unique admissibility restrictions on the decisions of  
     independent review organizations. . . .Because appeals  
     will be permitted only when the enrollee disagrees  
     with decision of the independent review organization,  
     the plan should be permitted to present evidence  
     regarding both the process regarding the conduct of  
     the independent external review and the substance of  
     the reviewing organization's decision. 








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  The Argument Against Admissibility  :  In contrast to these  
arguments in favor of admitting at least some aspects of the  
independent review process, the Consumer Attorneys of California  
wrote the Committee to repeat their deep concerns about the  
permitting any aspect of these proposed review programs to be  
admitted in subsequent judicial proceedings.  They write:

     We strongly believe that for this external review  
     process to work fairly and effectively, any decision  
     reached by the reviewer or issued by the regulating  
     authority - whether favorable or unfavorable to the  
     enrollee - must be inadmissible in any subsequent  
     legal action. . . .
     The external review process must not deprive consumers  
     of their right to seek redress under any other remedy  
     available in law.  With appropriate safeguards and the  
     right to sue, the external review process may allow  
     some enrollees to receive an expeditious and  
     inexpensive determination of their dispute.  However,  
     it must be recognized that this procedure is intended  
     to be an informal process in which the enrollee will  
     generally not hire an attorney.

     Banning admissibility of any decision reached in these  
     informal procedures not
     only encourages the parties to participate, but  
     assures their full and frank participation in the  
     process.  In addition, significant due process issues  
     require that the decision from these informal  
     procedures not be admissible. . . .Under this informal  
     review process the appointed reviewer (or reviewers)  
     will review the provider recommendations and medical  
     records.  However, there is no requirement for a  
     hearing at which either party may appear and provide  
     testimony or explanation.  There is no opportunity for  
     either party to examine the expertise and clinical  
     experience of the reviewer, or to examine his or her  
     biases and credibility.  Neither party is permitted to  
     cross-examine the reviewer to learn on what basis the  
     reviewer made his or her decision, nor to learn  
     whether the reviewer considered specific relevant  
     evidence.  There is no opportunity for either party to  
     challenge any of the evidence relied upon by the  
     reviewer, or to introduce other experts to expand upon  








                                                          AB 55
                                                          Page  15

     or rebut findings made by the reviewer. . .  
     .Instructing a jury to consider the reviewer's  
     decision as nothing more than the opinion of any other  
     expert simply will not overcome the jury's inherent  
     and perfectly normal acceptance of that expert's  
     conclusions as more valuable, more meaningful, and  
     more significant; merely because the "government"  
     appointed that expert.

  Staff Counsel Comment:   Although the experts above all ably  
highlight the difficult and conflicting evidentiary issues  
raised by the question of admissibility of independent  
review procedures and decisions, it would appear the basis  
of the Committee's determination last year to preclude the  
admissibility of all aspects of any independent review  
process remains sound.  Although it is argued that barring  
admissibility of a reviewer's recommendations and decisions  
will benefit only the enrollee, it would seem clear that  
banning the decision and recommendations of the reviewer  
does not prevent the plan from introducing all the relevant  
evidence and reasoning used by the reviewer during the  
subsequent trial.  In other words, notwithstanding a  
statutory admissibility bar, a plan still would be able to  
present this evidence to the jury.  However, a trial  
setting provides the enrollee with full due process rights  
to cross-examine the witnesses, raise inconsistencies in  
the evidence, investigate potential biases of witnesses,  
and introduce other evidence that the plan or reviewer has  
ignored or dismissed.  This is not the case in the more  
informal review process.  Consequently, banning  
admissibility of the decision does not appear to hinder the  
plan, but rather properly assures that the parties have  
full and equal rights to present the relevant evidence to  
the jury.

  Possible Committee Amendment  :  Should the Committee  
conclude that admitting any aspect of the proceedings of  
the proposed independent medical review into evidence is  
inappropriate in a subsequent judicial proceeding, it may  
wish to amend the bill with the following language  
identical to that adopted last year in the various  
independent review bills that came before it:

On page 30, line 15, insert:  "(g) Nothing about the  
independent review process established by this article,  








                                                          AB 55
                                                          Page  16

including but not limited to, the analysis,  
recommendations, and conclusions of the review panel, shall  
be admissible in any subsequent proceeding."
      
Related Pending Legislation  :  Several bills have also been  
introduced this session to require, through varying means,  
health plans to establish an independent medical review system.   
These bills include 
AB 1621 (Thomson) noted above, SB 189 (Schiff) and SB 254  
(Speier).  

  REGISTERED SUPPORT / OPPOSITION  :   

  Support   (As communicated to the Assembly Health Committee)

California School Employees Association
California Psychiatric Association
California Teachers Association
Consumer Attorneys of California (if amended)
Union of American Physicians and Dentists
Western Center on Law and Poverty (with amendments)
 
  Opposition   (As communicated to the Assembly Health Committee)

Association for California Tort Reform
Blue Cross of California 
California Association of Health Plans 
California Association of Health Underwriters
California Chamber of Commerce 
California Physician Groups Council
Health Insurance Association of America
Health Net  
New York Life


  Analysis Prepared by  :   Drew Liebert  and Donna S. Hershkowitz /  
JUD. / (916) 319-2334