[Congressional Bills 103th Congress]
[From the U.S. Government Publishing Office]
[H.R. 2089 Introduced in House (IH)]

103d CONGRESS
  1st Session
                                H. R. 2089

    To promote the use of State-coordinated health insurance buying 
programs and assist States in establishing Health Insurance Purchasing 
    Cooperatives, through which small employers may purchase health 
                   insurance, and for other purposes.


_______________________________________________________________________


                    IN THE HOUSE OF REPRESENTATIVES

                              May 12, 1993

   Mr. Brown of California introduced the following bill; which was 
  referred jointly to the Committees on Energy and Commerce, Ways and 
                        Means, and the Judiciary

_______________________________________________________________________

                                 A BILL


 
    To promote the use of State-coordinated health insurance buying 
programs and assist States in establishing Health Insurance Purchasing 
    Cooperatives, through which small employers may purchase health 
                   insurance, and for other purposes.

    Be it enacted by the Senate and House of Representatives of the 
United States of America in Congress assembled,

SECTION 1. SHORT TITLE.

    This Act may be cited as the ``Health Insurance Purchasing 
Cooperatives Act''.

SEC. 2. HEALTH INSURANCE PURCHASING COOPERATIVES GRANT PROGRAM.

    (a) In General.--The Secretary shall award grants to States, which 
submit applications and otherwise meet the requirements of this Act, to 
assist such States in establishing coordinated buying programs through 
which small employers may purchase health insurance for their 
employees.
    (b) Application Requirements.--To be eligible to receive a grant 
under this section, a State shall prepare and submit to the Secretary 
an application in such form, at such time, and containing such 
information, certifications, and assurances as the Secretary shall 
reasonably require, including a certification that--
            (1) the State has, through State law, executive order, or 
        regulation, initiated the steps necessary to establish a 
        coordinated buying program that meets the requirements of 
        subsection (d), through which each small employer in the State 
        desiring to purchase health insurance for its employees shall 
        purchase such insurance; or
            (2) in the case of a State which the Secretary identifies, 
        in consultation with the National Association of Insurance 
        Commissioners, as--
                    (A) requiring State legislation (other than 
                legislation appropriating funds) to establish a 
                coordinated buying program that meets the requirements 
                of subsection (d); and
                    (B) having a legislature that does not meet during 
                the first year after the date of enactment of this Act 
                in a legislative session in which such legislation may 
                be considered;
        the State has established a plan, to be fully implemented not 
        later than 2 years after the date on which the grant is awarded 
        to such State by the Secretary, for the establishment of a 
        coordinated buying program that meets the requirements of 
        subsection (d).
    (c) Use of Funds.--Amounts awarded under this section may be used 
to finance the administrative costs associated with planning, 
developing, and implementing a coordinated buying program, comprised of 
one or more Health Insurance Purchasing Cooperatives, for small 
employers. Such administrative costs may include the costs associated 
with--
            (1) engaging in education and outreach efforts to inform 
        small employers, carriers, and the public about the coordinated 
        buying program;
            (2) soliciting bids and negotiating with carriers to make 
        available health benefit plans, consistent with section 3, 
        through the coordinated buying program and one or more Health 
        Insurance Purchasing Cooperatives; and
            (3) preparing and disseminating the documentation required 
        by Federal agencies to certify participation in the coordinated 
        buying program and one or more Health Insurance Purchasing 
        Cooperatives.
    (d) Coordinated Buying Program.--To receive funding under this 
section, a State coordinated buying program shall--
            (1) be authorized and enforced under State law, executive 
        order, or regulation as the sole mechanism through which health 
        insurance for employees of small employers shall be purchased 
        in such State;
            (2) provide each small employer in the State with access to 
        health insurance for its employees and their dependents, 
        through one or more Health Insurance Purchasing Cooperatives 
        qualified under subsection (e);
            (3) require that each Health Insurance Purchasing 
        Cooperative participating in the State coordinated buying 
        program meet the requirements of section 5 with respect to 
        reporting data to a Regional Data Collection Center and 
        participating in the National Health Insurance Data System; and
            (4) meet such other criteria as reasonably required by the 
        Secretary, the National Health Board, or mandated under this 
        Act.
    (e) Health Insurance Purchasing Cooperative.--
            (1) Requirements.--To be a qualified Health Insurance 
        Purchasing Cooperative an entity shall--
                    (A) be a nonprofit entity established and regulated 
                in accordance with State law in a manner that will 
                ensure an economy of scale based on the State's 
                geographic and demographic characteristics;
                    (B) be designated by the State as the exclusive 
                agent for purchasing, coordinating, and administering 
                services among carriers on behalf of small employers 
                and their employees within a defined geographic area 
                (hereafter referred to in this section as a 
                ``district'');
                    (C) except as provided under paragraph (3), certify 
                that it will not contract with any carriers that deny, 
                limit, or condition coverage under (or benefits of) the 
                plan based on the health status, claims experience, 
                receipt of health care, medical history or lack of 
                evidence of insurability, of an individual;
                    (D) after the date that is 2 years after the date 
                of enactment of this Act, certify that it will not 
                contract with any carriers that do not meet the minimum 
                benefits requirements established by the National 
                Health Board under section 4;
                    (E) not less than annually, hold an open enrollment 
                period for all employees covered by the Health 
                Insurance Purchasing Cooperative health benefit plans;
                    (F) use adjusted community ratings (under which the 
                only factors that may be applied are age, gender, and 
                geography within a district) to determine the cost for 
                each covered employee or dependent; and
                    (G) meet such other criteria as reasonably required 
                by the State or the Secretary, or mandated under this 
                Act.
            (2) Activities.--Within its district, each Health Insurance 
        Purchasing Cooperative shall--
                    (A) provide for the comprehensive purchasing of 
                health insurance and services for all small employers;
                    (B) act as an agent for the small employers and, 
                based on the recommendations of the National Health 
                Board, assist the small employers, employees, and 
                dependents in determining appropriate health benefit 
                plans;
                    (C) solicit bids from and contract with carriers 
                for specific health benefit plans, which shall include 
                those benefits determined by the National Health Board 
                under section 4, and, notwithstanding any other 
                provision of Federal or State law--
                            (i) hold confidential proprietary 
                        information upon which estimates on bids are 
                        derived; and
                            (ii) issue contracts only to those carriers 
                        providing both cost effective and quality 
                        health benefits, plans, and services;
                    (D) administer all aspects of health insurance 
                coverage for all small employers, their employees and 
                dependents, including routine health benefits, COBRA 
                benefits, relevant Federal health insurance earned 
                income tax credits, and the collection of premiums paid 
                under section 1906 of the Social Security Act;
                    (E) inform employees and dependents about their 
                benefits, rights, and responsibilities and enable 
                employees and dependents to select benefits based on 
                standardized plans that compete in cost and quality; 
                and
                    (F) in a timely fashion, report, as required by 
                section 5, all relevant data, including health outcomes 
                data, to the appropriate Regional Health Insurance Data 
                Collection Center.
            (3) Exclusion of coverage.--Notwithstanding paragraph 
        (1)(C), a Health Insurance Purchasing Cooperative may, in 
        accordance with this subsection, contract with a carrier for a 
        health benefit plan that limits exclusion of coverage, with 
        respect to services related to treatment of a preexisting 
        condition, to a period not exceeding 6 months. The exclusion of 
        coverage shall not apply to services furnished to newborns.
    (f) Relation To Other Laws.--
            (1) Antitrust laws.--Notwithstanding any provision of the 
        antitrust laws, it shall not be considered a violation of the 
        antitrust laws for a State, in accordance with this section, to 
        develop a State coordinated buying program comprised of Health 
        Insurance Purchasing Cooperatives, or for any carrier, in 
        accordance with this section, to participate in such a program 
        or Cooperative.
            (2) Definition.--For purposes of this section, the term 
        ``antitrust laws'' means--
                    (A) the Act entitled ``An Act to protect trade and 
                commerce against unlawful restraints and monopolies'', 
                approved July 2, 1890, commonly known as the ``Sherman 
                Act'' (26 Stat. 209; chapter 647; 15 U.S.C. 1 et seq.);
                    (B) the Federal Trade Commission Act, approved 
                September 26, 1914 (38 Stat. 717; chapter 311; 15 
                U.S.C. 41 et seq.);
                    (C) the Act entitled ``An Act to supplement 
                existing laws against unlawful restraints and 
                monopolies, and for other purposes'', approved October 
                15, 1914, commonly known as the ``Clayton Act'' (38 
                Stat. 730; chapter 323; 15 U.S.C. 12 et seq.; 18 U.S.C. 
                402, 660, 3285, 3691; 29 U.S.C. 52, 53); and
                    (D) any State antitrust laws that would prohibit 
                the activities described in paragraph (1).
    (g) Authorization of Appropriations.--There are authorized to be 
appropriated to carry out this section, $25,000,000 for fiscal year 
1994, and $30,000,000 for each of the fiscal years 1995 through 1998.

SEC. 3. NATIONAL HEALTH BOARD.

    (a) In General.--There is hereby established a National Health 
Board (hereafter referred to in this section as the ``Board'') which 
shall be composed of 11 members to be appointed by the President by and 
with the advice and consent of the Senate not later than 6 months after 
the date of enactment of this Act.
    (b) Membership.--
            (1) Representation.--The membership of the Board shall 
        include individuals with national recognition for their 
        expertise in health insurance, health economics, health care 
        provider reimbursement, and related fields. In appointing 
        individuals under subsection (a), the President shall assure 
        representation of consumers of health services, large and small 
        employers, State and local governments, labor organizations, 
        and health care providers and carriers.
            (2) Chairperson.--The members of the Board shall elect a 
        Chairperson.
            (3) Terms.--Members of the Board shall be appointed to 
        serve for terms of 6 years, except that the terms of the 
        members first appointed shall be staggered so that the terms of 
        no more than 4 members expire in any year. The term of the 
        Chairperson shall be coincident with the term of the President. 
        Individuals appointed to fill a vacancy created in the Board 
        shall be appointed for the remainder of the term.
    (c) Duties.--
            (1) Precepts.--The Board shall establish Coordinated Buying 
        Program Precepts, that shall set forth criteria for--
                    (A) establishing a uniform data system that will 
                assist in designating qualified Health Insurance 
                Purchasing Cooperatives and carriers;
                    (B) determining and implementing a system for the 
                collection of relevant health outcomes data, including 
                quality monitors, functional status, expense reporting 
                methods (including the costs associated with providing 
                services within State coordinated buying program), 
                demographic and behavioral measures, and changes in 
                clinical conditions as a result of therapeutic 
                interventions expressed in Quality Life Years in a 
                manner that assumes confidentiality of patient 
                information; and
                    (C) determining and revising, if necessary, 
                appropriate minimum benefit requirements of a qualified 
                health benefit plan, consistent with section 4 and 
                developing additional benefit plans as necessary to 
                provide more extensive benefits.
            (2) Scientific basis.--To the extent practicable, the 
        precepts of the Board shall be derived from an evaluation of 
        the extant scientific literature and outcome data collected 
        under this Act.
            (3) Assistance to secretary.--The Board shall make written 
        recommendations on at least an annual basis to the Secretary 
        and the States in the planning, development, and implementation 
        of all components of the National Health Insurance Data System 
        established under section 5, including the determination of 
        health outcomes data to be collected through the standardized 
        universal electronic card, and shall provide such other 
        assistance as the Secretary or the States may request.
    (d) Miscellaneous.--
            (1) Authority.--The Board may--
                    (A) employ and fix the compensation of an Executive 
                Director and solicit other personnel (not to exceed 15) 
                as may be necessary to carry out its duties (without 
                regard to the provisions of title 5, United States 
                Code, governing appointments in the competitive 
                service);
                    (B) seek such assistance and support as may be 
                required in the performance of its duties from 
                appropriate Federal departments and agencies;
                    (C) enter into contracts or make other 
                arrangements, as may be necessary for the conduct of 
                the work of the Board (without regard to section 3709 
                of the Revised Statutes (41 U.S.C. 5)); and
                    (D) make advance, progress, and other payments 
                which relate to the work of the Board.
            (2) Compensation.--While serving on the business of the 
        Board (including traveltime), a member of the Board shall be 
        entitled to compensation at the per diem equivalent of the rate 
        provided for level IV of the Executive Schedule under section 
        5315 of title 5, United States Code, and while so serving away 
        from the member's home and regular place of business, a member 
        may be allowed travel expenses, as authorized by the 
        Chairperson of the Board.
            (3) Access to information, etc.--The Board shall have 
        access to such relevant information and data as may be 
        available from appropriate Federal agencies and shall assure 
        that its activities, especially the conduct of original 
        research and medical studies, are coordinated with the 
        activities of Federal agencies. The Board shall be subject to 
        periodic audit by the General Accounting Office.
            (4) Authorization of appropriations.--There are authorized 
        to be appropriated, $500,000 for each of the fiscal years 1994 
        through 1998.

SEC. 4. HEALTH BENEFITS.

    (a) Establishment of Requirements.--Not later than 18 months after 
the date of enactment of this Act, the National Health Board shall 
establish minimum benefit requirements for health benefit plans offered 
through Health Insurance Purchasing Cooperatives. Such minimum benefits 
shall include--
            (1) inpatient and outpatient hospital care, except that 
        treatment for a mental disorder is subject to the special 
        limitations described in paragraph (6)(A);
            (2) inpatient and outpatient physician services, except 
        that psychotherapy or counseling for a mental disorder is 
        subject to the special limitations described in paragraph 
        (6)(B);
            (3) diagnostic tests;
            (4) prenatal care and well-baby care provided to children 
        who are 1 year of age or younger;
            (5) preventive and early intervention services, including--
                    (A) well child care;
                    (B) pap smears; and
                    (C) mammograms; and
            (6)(A) inpatient hospital care for a mental disorder for 
        not less than 45 days per year, except that days of partial 
        hospitalization, residential care, or outpatient treatment may 
        be substituted for days of inpatient care according to a ratio 
        established by the Board; and
            (B) outpatient psychotherapy and counseling for a mental 
        disorder for not less than 20 visits per year provided by a 
        provider who is acting within the scope of State law and who--
                    (i) is a physician; or
                    (ii) meets the standards of subsection (e)(2)(B) 
                and is a duly licensed or certified clinical 
                psychologist or a duly licensed or certified clinical 
                social worker, a duly licensed or certified equivalent 
                mental health professional, or a clinic or center 
                providing duly licensed or certified mental health 
                services.
    (b) Exceptions.--Subsection (a) shall not be construed as requiring 
the Board to specify that a plan include payment for--
            (1) items and services that are not medically necessary; or
            (2) experimental services and procedures, except that the 
        Board may include coverage of routine medical costs associated 
        with peer-reviewed and approved protocols conducted in 
        connection with peer-reviewed and approved research programs, 
        pursuant to standards established by the Board.
    (c) Amount, Scope, and Duration of Certain Benefits.--Except as 
provided in subsection (b), a health benefit plan shall place no limits 
on the amount, scope, or duration of benefits described in paragraphs 
(1) through (3) of subsection (a).
    (d) Limitations.--
            (1) Panels and managed care systems.--Nothing in this 
        section or this Act shall prohibit a health benefit plan from 
        providing benefits for the items and services described in this 
        section through a managed care system, and from selecting 
        particular health care providers or types, classes, or 
        categories of health care providers to participate in such 
        managed care system. Such managed care system shall provide 
        reasonable access, as defined by the Board, to care by plan 
        enrollees.
            (2) Different levels of payments.--Nothing in this section 
        or this Act shall prohibit a health benefit plan from 
        establishing a different level of payments for reimbursement 
        for different health care providers furnishing the benefits for 
        the items and services described in this section.
            (3) Denial of payment to excluded providers.--Nothing in 
        this section or this Act shall require a health benefit plan to 
        make payment to any health care provider that is excluded from 
        participation in any Federal health care program.
    (e) Mental Health Care.--
            (1) Inpatient care.--Subject to the provisions of 
        subsection (d), inpatient hospital care described in subsection 
        (a)(6)(A) shall include reimbursement for professional care 
        provided to the individual while the individual is receiving 
        such inpatient care, by a physician or duly licensed or 
        certified clinical psychologist operating within the scope of 
        practice of the physician or psychologist, as determined 
        appropriate under State law. Nothing in this subsection shall 
        be construed to modify hospital practices with regard to scope 
        of practice, admitting privileges, or billing arrangements.
            (2) Outpatient care.--
                    (A) Use of providers.--Subject to the provisions of 
                subsection (d), a health benefit plan that provided 
                benefits with respect to outpatient psychotherapy 
                described in subsection (a)(6)(B) prior to January 1, 
                1994, shall not be required under such subsection to 
                provide benefits for outpatient psychotherapy provided 
                by any health care provider (or type, class, or 
                category of health care provider) described in 
                subsection (a)(6)(B)(ii), other than duly licensed or 
                certified clinical psychologists and health care 
                providers being used by the plan on January 1, 1994.
                    (B) Standards for certain providers.--The Board 
                shall establish standards that providers referred to in 
                subsection (a)(6)(B)(ii) must meet to be eligible for 
                payment under a health benefit plan and such standards 
                shall require that such providers have training and 
                education equivalent to a licensed clinical social 
                worker (as defined in title XVIII of the Social 
                Security Act).
    (f) Added Benefit Plans.--Not later than 24 months after the date 
of enactment of this Act, the Board shall establish minimum benefit 
requirements for two additional health benefit plans that--
            (1) shall provide benefits more extensive or more 
        innovative than those provided by the plan developed under 
        subsection (a); and
            (2) may be compared on the basis of cost and quality 
        outcome measures.
    (g) Studies.--
            (1) Initial report.--Not later than 3 years after the date 
        of enactment of this Act, the Board shall--
                    (A) review the appropriateness of the minimum 
                benefits and services required to be covered under 
                subsection (a); and
                    (B) prepare and submit to the Secretary and the 
                appropriate committees of Congress a report concerning 
                the cost-effectiveness and desirability of such 
                benefits and services and making recommendations for 
                changes in the list of such benefits and services.
            (2) Biennial report.--Not later than 2 years after the date 
        on which the report is submitted under paragraph (1), and every 
        2 years thereafter, the Board shall prepare and submit to the 
        Secretary and the appropriate committees of Congress a report 
        updating the preceding report and reviewing, consistent with 
        paragraph (1), the additional benefits and services included in 
        the plans developed under subsection (f).
    (h) Exemption From HMO Requirements.--Section 1301 of the Public 
Health Service Act (42 U.S.C. 300e) is amended by adding at the end 
thereof the following new subsection:
    ``(d) The provisions of this title relating to health services 
offered by a health maintenance organization shall not apply with 
respect to those health maintenance organizations that provide services 
that meet the requirements for health insurance plans offered through 
Health Insurance Purchasing Cooperatives under section 4 of the Health 
Insurance Purchasing Cooperatives Act.''.

SEC. 5. NATIONAL HEALTH INSURANCE DATA SYSTEM.

    (a) In General.--Using advanced technologies to the maximum extent 
practicable, the Secretary shall establish and maintain a National 
Health Insurance Data System, which shall be comprised of--
            (1) a centralized National Data Base for Health Insurance 
        and Health Outcomes Information;
            (2) a network of no more than five Regional Health 
        Insurance Data Collection Centers; and
            (3) a standardized, universal mechanism for electronically 
        processing health insurance and health outcomes data.
    (b) National Data Base for Health Insurance Information.--The 
National Data Base for Health Insurance Information shall--
            (1) be centrally located;
            (2) rely on advanced technologies to the maximum extent 
        practicable; and
            (3) be readily accessible by each State coordinated buying 
        program for data input and retrieval.
    (c) Regional Health Insurance Data Collection Centers.--The 
Secretary shall designate not more than five regional centers, to be 
located throughout the United States, for the initial collection and 
analysis of data on each State coordinated buying program, as described 
in section 3(c)(1)(B), and such other information as determined useful 
to the Secretary or the National Health Board. The regional centers 
shall transmit relevant data, as determined appropriate by the 
Secretary and the National Health Board, to the National Data Base for 
Health Insurance and Health Outcomes Information.
    (d) Electronic Data Collection Card.--The Secretary, upon the 
recommendation of the National Health Board, shall--
            (1) establish uniform billing and claims forms and 
        mandatory reporting requirements, including information on 
        member eligibility, benefits, use, outcomes, and efficacy, 
        which shall be adopted for use by each State and State 
        coordinated buying program receiving funding under section 2; 
        and
            (2) ensure that no State receives funding under this Act if 
        carriers in such State do not agree to issue to each 
        participant in the State coordinated buying program an 
        electronic data processing card approved by the Secretary that 
        shall--
                    (A) contain information on billing, eligibility, 
                and other financial, administrative, and health 
                outcomes matters, as determined necessary by the 
                Secretary and the National Health Board, which can be 
                conveyed electronically to a regional data processing 
                center; and
                    (B) enable health care providers to enter 
                information into a participant's file concerning 
                administrative matters, treatment, such as diagnosis 
                based on standard codes, and outcome, except that 
                participating health care providers must agree to 
                provide data in standard format, which shall be 
                established by the Secretary and the National Health 
                Board.
    (e) Religious Objections.--Nothing in this Act shall be construed 
to require any State coordinated buying program or Health Insurance 
Purchasing Cooperative to compel any person to undergo any medical 
screening, examination, diagnosis, or treatment or to accept any other 
health care or services provided under a health benefit plan for any 
purpose (other than for the purpose of discovering and preventing the 
spread of infection or contagious disease or for the purpose of 
protecting environmental health), if such person objects (or, in case 
such person is a child, his parent or guardian objects) thereto on 
religious grounds.
    (f) Confidentiality.--The Secretary, upon the recommendation of the 
National Health Board, shall ensure that all patient information 
collected under this section is managed so that confidentiality is 
protected.
    (g) Authorization of Appropriations.--There shall be authorized to 
be appropriated, annually, $1,000,000 for fiscal years 1994 through 
1998.

SEC. 6. DEFINITIONS.

    As used in this Act:
            (1) Carrier.--The term ``carrier'' means any person or 
        entity that offers a health benefit plan, whether through 
        insurance or otherwise, including a licensed insurance company, 
        a prepaid hospital or medical service plan, or a health 
        maintenance organization.
            (2) Eligible employee.--The term ``eligible employee'' 
        means, with respect to an employer, an employee who normally 
        performs on a monthly basis at least 30 hours of service per 
        week for that employer.
            (3) Health benefit plan.--The term ``health benefit plan'' 
        means any hospital or medical service policy or certificate, 
        hospital or medical service plan contract, or health 
        maintenance organization group contract, but does not include 
        any of the following offered by a carrier--
                    (A) accident only, dental only, disability only 
                insurance, or long-term care only insurance;
                    (B) coverage issued as a supplement to liability 
                insurance;
                    (C) workmen's compensation or similar insurance; or
                    (D) automobile medical-payment insurance.
            (4) Health maintenance organization.--The term ``health 
        maintenance organization'' has the meaning given the term 
        ``eligible organization'' in section 1876(b) of the Social 
        Security Act.
            (5) NAIC.--The term ``NAIC'' means the National Association 
        of Insurance Commissioners.
            (6) Preexisting condition.--The term ``preexisting 
        condition'' means, with respect to coverage under a health 
        benefit plan issued to a small employer, employee or dependent 
        by a carrier, a condition which has been diagnosed or treated 
        during the 3-month period ending on the day before the first 
        date of such coverage (without regard to any waiting period).
            (7) Secretary.--The term ``Secretary'' means the Secretary 
        of Health and Human Services.
            (8) Small employer.--The term ``small employer'' means, 
        with respect to a calendar year, an employer that normally 
        employs at least 1 but less than 51 eligible employees on a 
        typical business day. For the purposes of this paragraph, the 
        term ``employer'' includes a self-employed individual.

SEC. 7. INCREASE IN DEDUCTIBLE HEALTH INSURANCE COSTS FOR SELF-EMPLOYED 
              INDIVIDUALS FOR INSURANCE PURCHASED THROUGH A HEALTH 
              INSURANCE PURCHASING COOPERATIVE.

    (a) In General.--Paragraph (1) of section 162(l) of the Internal 
Revenue Code of 1986 (relating to special rules for health insurance 
costs of self-employed individuals) is amended by striking ``equal to'' 
and all that follows and inserting the following: ``equal to--
                    ``(A) 100 percent of the amount paid during the 
                taxable year for insurance which is purchased through a 
                Health Insurance Purchasing Cooperative under the 
                Health Insurance Purchasing Cooperatives Act and which 
                constitutes medical care for the taxpayer, his spouse, 
                and dependents, and
                    ``(B) 25 percent of the amount paid during the 
                taxable year for insurance not described in 
                subparagraph (A) which constitutes medical care for the 
                taxpayer, his spouse, and dependents.''.
    (b) Permanent Deduction.--Section 162(l) of such Code is amended by 
striking paragraph (6).
    (c) Effective Date.--The amendments made by this section shall 
apply to taxable years beginning after December 31, 1993.

                                 <all>

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