[Congressional Record Volume 146, Number 28 (Tuesday, March 14, 2000)]
[House]
[Pages H970-H974]
From the Congressional Record Online through the Government Publishing Office [www.gpo.gov]
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HMO LEGISLATION
The SPEAKER pro tempore (Mr. Isakson). Under the Speaker's announced
policy of January 6, 1999, the gentleman from Iowa (Mr. Ganske) is
recognized for 60 minutes.
Mr. GANSKE. Mr. Speaker, I rise tonight to clarify points about HMO
legislation before Congress for my colleagues, particularly members of
the conference committee, and to specifically address two memoranda
that have been recently released by the Heritage Foundation and one by
the Blue Cross/Blue Shield Association.
Mr. Speaker, I refer to the Heritage Foundation Backgrounder N1350,
The Patients' Bill of Rights, Prescription for Massive Federal Health
Regulation, by John Hoff; to Heritage Foundation Executive Memorandum
658, Why the Texas HMO Liability Law is Not a Proven Model for
Congress; and to a letter by Mary Nell Leonard, Senior Vice President
of Blue Cross/Blue Shield, with accompanying memo, A Regulatory
Quagmire, Questions and Answers about the Bipartisan Consensus Managed
Care Improvement Act of 1999.
Mr. Speaker, these memos are primarily a rehash of previous arguments
that have been made frequently on the floor. We had several days of
full debate on the Bipartisan Consensus Managed Care Improvement Act,
and we debated all of these issues. However, these repackaged arguments
deserve comment, I think, precisely because they are so specious.
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Let me start with the Backgrounder. It makes three main charges: that
the House bill would encourage costly litigation, expose employers to
risk of litigation over benefits, and would impose powerful new Federal
regulations on private health plans.
The organization of this paper is clever in that there is a mixture
of accuracy and distortions in discussing the House bill. But it
primarily tries to scare conservative legislatures with the bogeyman of
massive Federal regulation. The summary of this paper bemoans the
establishment of an intrusive new Federal bureaucracy with new rules on
utilization review, internal and external review, grievance processes,
drug formularies, clinical trials, patient information, and doctors'
incentive arrangements, among others.
This paper makes it seem as if these rules are proposed just for the
fun of it, as if these new regulations would be there just for their
own sake. Well, Mr. Speaker, the gentleman from Georgia (Mr. Norwood),
the gentleman from South Carolina (Mr. Graham), the gentleman from
Georgia (Mr. Barr), myself, and many other conservatives do not propose
regulations just for the hell of it. The paper leaves unmentioned the
reasons for these rules for HMOs, reasons why 80 percent of the
American public wants Congress to fix this problem and fix it now.
Let me give my colleagues some real-life examples of why new rules
are necessary for HMOs. This little boy lost his hands and his feet
because an HMO decided he could travel 60 miles to an emergency room
instead of going to the nearest emergency room. This woman lost her
life because an HMO gagged her doctors. This woman's HMO would not pay
her hospital bills because, when she fell off a cliff and went to the
emergency room, she had not phoned for prior authorization.
Mr. Speaker, if regulation is bad simply because it is regulation,
then we can just pack up the Federal and State governments, and we can
all go home. Of course, we would soon have monopolies controlling
everything; water we could not drink and buildings that fall down in
earthquakes.
Mr. Speaker, a year ago we talked an awful lot on this floor about
the rule of law. Well, without patient protection legislation, we will
sure continue to have lawless HMOs. If there are no Federal standards
in health care, then who does ensure quality and solvency? Who fights
against fraud in the insurance industry?
Well, the State should do it, some say. Okay. Then let us repeal
ERISA, the Employee Retirement Income Security Act, which preempts
State oversight of employer health plans. Let us turn it back to the
States. Oh no, would say the group health plans. We do not want State
oversight. But then again, we do not want Federal oversight either. To
be quite frank, the HMOs say, we do not want any oversight. So just
leave ERISA alone, we will police ourselves, thank you.
Well, Mr. Speaker, maybe we ought to ask that little boy who lost his
hands and feet, or the family that lost its mother how well self-
imposed standards in the HMO industry work.
I could give a reasoned rebuttal to every page of this Backgrounder,
but we do not have time tonight to go over this sentence by sentence.
So let me just give my colleagues a few examples.
On page 4 this paper says the House's bill's external appeals board
is ``biased'' because, and this is from the Backgrounder, ``neither the
entity nor its members can have what is considered to be a conflict of
interest or have familial, financial, or professional relationships
with the insurer, the health plan, the plan sponsor, the doctor who
provided the treatment involved, the institution at which the care is
provided, or with the manufacturer or medical supplier involved in the
coverage decision.'' That is in the Backgrounder.
This Backgrounder says the board is ``biased'' because it does not
have a specific statutory language prohibition against one of those
peer reviewers having a familial relationship with the patient but does
prohibit a relationship with the HMO. Well, Mr. Speaker, that is just
plain wrong. The bill that passed on this floor with 275 votes
specifically says, ``A clinical peer or other entity meets the
independence requirement of this paragraph if the peer or entity does
not have a familial, financial, or professional relationship with any
related party.'' Mr. Speaker, what could be clearer than that?
Or how about the discussion on the ``medical necessity quandary'' on
page 5 of this Backgrounder? Now, I have spoken many times on this
floor about the Employee Retirement Income Security Act and medical
necessity. Indeed, the Heritage Backgrounder tries to use some of my
own arguments.
Under current Federal law, HMOs can define as medically necessary or
unnecessary anything they want. One HMO, for example, has defined
medically necessary as ``the cheapest, least expensive care.'' That HMO
could deny surgical correction of this boy's cleft palate because it
would be cheaper to just provide a plastic upper denture. Of course,
his speech would not be very good, but it sure does meet that plan's
definition of medical necessity. After all, that would be cheap.
The bipartisan House bill corrects that travesty by giving the
external appeals board the final say in determining medical necessity,
as long as the treatment is not explicitly excluded from coverage in
the contract. The review panel can consider many things in its
decision, even the plan's own guidelines, but is not ``bound'' by those
planned guidelines.
So the author in this Backgrounder rightly states that outcomes data
can provide valuable guidance but cannot match the characteristics of
individual patients, thus echoing arguments that I have made on this
floor many times. Amazingly, he then, the author of this paper, then
criticizes the House bill's external appeals provision exactly because
it recognizes that reality and states that the appeals board can
consider outcome studies but is not bound by them.
But in the very next paragraph in this paper, we get to what the HMOs
really do not like about that provision in the Bipartisan Consensus
Managed Care Improvement Act that passed this House, and that is that
doctors, not HMO bureaucrats, would be making those medical decisions.
As this paper states it, ``The legislation would punt these crucial
questions to the subjective consideration of external reviewers.'' Mr.
Speaker, note the pejorative words punt and subjective. Where in this
paper is the criticism of the ``subjective consideration'' of HMOs
looking at their bottom line?
The author goes on to say, ``The bill will turn the determination of
what is covered over to government-controlled external reviewers who
are directed to make their decision regardless of what the private
health plan and its enrollees agree upon.'' Once again negative
adjectives, like government-controlled, show the writer's prejudice.
For heaven's sake, we have already established that the House bill
reviewers are independent, not government-controlled. What the HMOs
really do not like is that the peer reviewers in the bill that passed
this House are not HMO controlled.
Furthermore, as I already stated, the external panel cannot overrule
specifically excluded benefits. But that is rarely where the dispute
is. It usually involves denial of care for treatment that fit well
within standards of care.
To show my colleagues how abusive the HMO industry can be on this
issue of medical necessity, listen to testimony that a former HMO
medical reviewer gave before my congressional committee in which she
admitted that she had made medical decisions for HMOs that had killed
people. She said, ``I wish to begin by making a public confession.''
Mr. Speaker, this is a former HMO medical reviewer. She said, ``In the
spring of 1987, as a medical reviewer, I caused the death of a man.
Since that day, I have lived with this act and many others eating into
my heart and soul. The primary ethical norm is to do no harm. I did
worse; I did death. Instead of using a clumsy bloody weapon, I used the
simplest of tools, my words. This man died because I denied him a
necessary operation to save his heart. I felt little pain or remorse at
the time. The man's faceless distance soothed my conscience. Like a
skilled soldier, I was trained for this moment. When moral qualms
arose, I was to remember `I am not denying care, I am only denying
payment.' ''
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This former HMO medical reviewer then listed the many ways that
managed health care plans deny care to patients, but she emphasized one
particular point: the right of HMOs to decide what care is medically
necessary. She said, ``There is one last activity that I think deserves
a special place on this list, and this is what I call the smart bomb of
cost containment, and that is medical necessity denials.
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``Even when medical criteria is used, it is rarely developed in any
kind of standard traditional clinical process, it is rarely
standardized across the field, the criteria is rarely available for
prior review by the physicians or members of the plan.''
Well, Mr. Speaker, I have a complete discussion of this critical
issue in this Dear Colleague. I will be sending this Dear Colleague to
every Member of the House and the Senate. I especially hope that the
conferees, at least, will take the time to read this because this is
one of the two or three most important issues before the conference.
The next several pages of this Heritage paper describes some of the
House bill's provisions, again, without providing a context of the
problems with HMOs that make these provisions important. The author
even criticizes the prohibition on gag rules that some HMOs have tried
to impose on doctors.
For heaven's sake, Mr. Speaker, over 300 Members of the House signed
on to a bill that would ban HMOs from trying to keep doctors from
telling patients the whole story about their treatment options.
Apparently, the Heritage Foundation also does not like the fact that
Congress has already prohibited Medicare HMOs from paying doctors to
limit care. This is on page 9 of this Backgrounder.
The Norwood-Dingell-Ganske HMO reform bill uses the same language
that the vast majority of Members of this House and the Senate voted on
for Medicare to prohibit HMOs from paying doctors to limit care.
I am a physician, and I want to tell my colleagues that there should
not be a conflict of interest in doctors providing needed care to their
patients. Yet some HMOs pay a doctor more if he or she withholds
referrals or treatment.
Congress has already overwhelmingly said that this practice is
ethically wrong. So, as an aside, and I hope somebody from the Supreme
Court, some clerk, is listening to this special order, I think the
Supreme Court should consider that Congress has already legislated on
this behavior of HMOs as it considers the Hurdrick case that is
currently on its docket.
Well, this paper even calls the bipartisan bill an attack on fee-for-
service coverage. Wrong again. In fact, the House bill recognizes the
difference between HMOs and fee-for-service plans and exempts those
fee-for-service plans from requirements that are pertinent to HMOs.
The House bill would, however, require PPOs and point-of-service
plans to follow fair utilization reviews, a fair internal and external
appeals process, and require that enrollees be given adequate
information about the plan. ERISA plans do not currently have to do
that. And 275 bipartisan supporters of the House bill do think that
every plan covering everyone in this country, regardless of the type,
should follow those minimum requirements.
Now, the Blue Cross paper, ``a regulatory quagmire,'' tries to make
some similar points on regulation. So my comment will apply to both. I
would note that Blue Cross owns HMOs, so caveat emptor.
Well, how would the House bill work? As in the Health Insurance
Portability and Accountability Act, the provisions of the House bill
form a Federal policy floor. States are encouraged to bring their laws
into compliance. If a State fails to enforce the law, then the Federal
Government would. Same way under the Health Insurance Portability Act.
And under the Health Insurance Portability Act, all States except four
have already complied.
Now, on the patient protection issue, most States have already
enacted some of the provisions of the House HMO reform bill into State
law. For example, 50 States have enacted internal review, 50 States
have enacted access to information, 46 States gag prohibition, 41
States emergency care provisions, 32 States external review, 34 States
direct access to OB-GYNs, 24 States continutity-of-care provisions.
Mr. Speaker, it will not be hard for those States to comply. But the
important point to note is that no matter how good a State's patient
protections law are, these State laws generally do not apply to ERISA
plans. And that is exactly why we need Federal legislation to protect
the people who receive their insurance from their employer.
Now, the HMO industry complains that the Norwood-Dingell-Ganske bill
would result in dual regulation and be confusing to consumers. But we
have dual regulation today. We already have complex dual regulation
that differs from jurisdiction to jurisdiction.
The Bipartisan Consensus Managed Care Improvement Act will actually
simplify things for consumers. What is clear today is that the consumer
in an ERISA health plan, an employer health plan, has basically nowhere
to go to turn for help. But if our bipartisan House bill would become
law, the vast majority of consumers would be able to go to their State
insurance commissioners for questions about their rights because all
States would have a minimum standard.
Furthermore, I would point out that it can be hardly valid to
criticize the House bill for Federal-State conflicts. We have had a
Federal-State system of regulation of commerce for 200-plus years.
Yes, if the Norwood-Dingell-Ganske bill becomes law, there will be
questions of Federal-State jurisdiction to work out, as there is in any
bill. And I would say, what is new?
Now, as an example of delay of implementation, the Blue Cross memo,
the one that says ``quagmire of regulation,'' points out that the
Health Insurance Portability Act still has not been fully implemented
on the privacy regulations. Well, I should point out that Congress had
something to do with that, since Congress did not meet its own deadline
on legislation for privacy. But I sure do not see any groundswell
calling for repeal of the Health Insurance Portability Act. In fact,
Mr. Speaker, I have had many constituents thank me for their health
insurance portability.
In any congressional bill, there has to be the right balance between
prescription and flexibility. The House bill provides a reasonable
balance. But on page 6, again of this Heritage Backgrounder, the
legislative language of our bill, the House bill, is criticized for
being too loose. But then, Mr. Speaker, on page 11, the same bill is
criticized for being too rigid. There is just no pleasing those
opponents of HMO reform.
Let us discuss the liability issue a bit. The HMO community is
clearly getting nervous that Governor Bush says he supports the Texas
Health Care Liability Act of 1997. So Heritage came out with a memo
entitled ``Why the Texas HMO Liability Law is not a Proven Model for
Congress.''
However, if you actually read the memo, you will be struck with how
similar the House bill is to the Texas law, which Governor Bush says is
working just fine, thank you. No avalanche of lawsuits. No
extraordinary increase in premiums. No Diaspora of HMOs from Texas.
Now, the Heritage memo notes that, on September 1, 1997, the Texas
legislature passed the Texas Health Care Liability Act, according to
Heritage, by a ``sizable majority.'' Sizable majority indeed. The bill
passed the Texas Senate unanimously. It passed the Texas House 120-21.
It was veto proof.
Well, what did the Texas bill do? According to this Heritage paper,
it ``created a new cause of action against three entities in the event
of a failure to exercise ordinary care. These entities are: a health
insurance carrier, a health maintenance organization, or other managed
care entity.''
Mr. Speaker, in plain language, the Texas liability bill allowed
patients to sue HMOs for negligence, just plain language.
So what has happened in Texas since the bill was passed? Well, in
September 1998, Federal judge Vanessa Gilmore refused to void the Texas
right to sue. On October 18, 1999, the first case was filed ``Plocica
v. NYLCare.''
The HMO wanted the case moved to Federal court, but the Federal court
remanded it back to State court. But it
[[Page H973]]
is interesting to know a little bit about this case because it makes
the case for having a strong enforcement provision in a bill that
Congress would pass.
Mr. Plocica was suicidal in a hospital in Texas. His treating doctor
thought he should stay in the hospital, needed more psychiatric care.
His HMO, NYLCare, said, no, we are sending you home. Under State law,
NYLCare should have taken their treatment denial to what Governor Bush
calls the ``IRO Panel,'' the Independent Review Organization Panel. But
NYLCare ignored State law, so Mr. Plocica went home. That night he
drank half a gallon of antifreeze, and he died a horrible death. His
family has sued NYLCare for breaking Texas law.
It should be noted that, under current Federal ERISA law, NYLCare
would be liable for only the cost of care denied, in this case I guess
the cost of a day or two in the hospital. That is hardly justice to a
family that has just lost its father and hardly a disincentive to an
HMO from not following the law.
There have been only a few cases filed under Texas law. Heritage says
it is too early for this to be accurate. I would point out that Texas
has a 2-year statute of limitations on these cases.
What you see is what you have got. If the cases are not filed by now,
they never will be. The Texas law exempts employers from liabilities
stating ``this chapter does not create any liability on the part of an
employer or employer group, purchasing organization, or a pharmacy
licensed by the State Board of Pharmacy that purchases coverage or
assumes risk on behalf of its employees.''
Mr. Speaker, the Norwood-Dingell-Ganske bill is written differently,
for the following reason: Unlike State-regulated plans, ERISA, the
Employee Retirement Income Security Act, provides liability preemption
for self-insured plans, some of which are self-administered or actually
are HMOs owned by the company.
Now, I am referring here to section 302(a) of the Bipartisan
Consensus Managed Care Reform Improvement Act of 1999. This section
creates a limited exception to ERISA's general ``preemption'' of State
laws that relate to employee benefit plans. This exception only applies
to State law causes of action against any person based on personal
injury or wrongful death resulting from providing or arranging for
insurance, administrative services or medical services by such person
to or for a group health plan.
So that is kind of complicated language. Let me see if I can explain
this a little simpler. This language does not, let me repeat, ``does
not'' disturb ERISA preemption of State law actions against a plan
sponsor except, ``except'' for the exercise of discretion by an
employer on an employee's treatment that has resulted in a personal
injury to that patient.
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Other decisions by plan sponsors, including setting up a uniform
benefit plan, is not, let me repeat, is not affected by section 302(a)
of the Norwood-Dingell-Ganske bill. Opponents to our legislation claim
that the bipartisan bill would subject employers to a flood of lawsuits
in State courts over all benefit decisions and suggest that employers
would be forced to abandon health insurance benefits.
Mr. Speaker, according to a memorandum done by one of the leading
ERISA labor law firms in Washington, Gardner, Carton and Douglas, this
memorandum, which I will be happy to share with any of my colleagues,
this is simply not correct. I will be happy to provide this brief to
anyone who desires a copy.
The gentleman from Georgia (Mr. Norwood) and I and the gentleman from
Michigan (Mr. Dingell) have always wanted to protect innocent employers
from liability. The vast majority of businesses, certainly small
businesses, simply contract with an HMO to provide health coverage for
their employees. They do not get involved with the HMO's decisions.
So we wrote protections for businesses into our bill, the bill that
passed this House. Those provisions are discussed in this brief, which
makes four main points in a well-documented and scholarly review.
First, lawsuits would not be against employers. Under current ERISA
law, suits seeking State law remedies for injury or death of group
health plan participants are already allowed in some jurisdictions.
Those cases show us that suits are normally brought against the HMO,
not against the employers. Why? Because employers are generally not
involved in treatment decisions, the type of decisions that lead to an
employee's injury or death. Ordinary benefits decisions, such as
setting up a benefit plan, are not affected by our bill.
Second, employer exposure would be limited. If an employer exercises
discretion in making a benefit claim decision under its group health
plan and that decision results in injury or death, then the section in
our bill makes an exception to the ERISA preemption and would allow an
employee to sue in State court, but to recover a patient must first
prove that the sponsor exercised discretion which resulted in the
injury or death and then must prove all elements of a State law cause
of action based on the employer's conduct in making the decision on
that particular claim. The injured patient must have a viable State law
cause of action because section 302(a) in our bill only creates an
exception to the preemption and does not create a new cause of action.
Three, the statute's plain meaning limits employer liability.
According to a thorough review of the law in this brief, the brief by
Gardner, Carton and Douglas from September 27, 1999, the liability
provisions in this House bill that protect employers would be
interpreted under the Supreme Court's well established, quote, plain
meaning, unquote, analysis. Such an analysis supports the bill's clear
intention to continue to prevent any liability suits against employers
that do not exercise discretion that results in injury or death.
Specific language in our bill states that other types of discretionary
employer language would not be affected and would not be subject to
State tort law claims.
The Heritage interpretations in this backgrounder simply ignore the
quote, plain meaning, unquote, language of the Supreme Court.
Number 4, employer health plans would not be destroyed. The limited
legal exposure of employers in the House bill will not cause them to
abandon health insurance for their employees. The experience of
nonERISA group health plans supports this. A recent study by Kaiser
Family Foundation compared ERISA health plans to nonERISA employer
health plans, such as CalPERS or the State of Colorado. That study
showed that the incidents of lawsuits and costs against nonERISA health
plans, where an employee can sue the health plan, is very low, in the
range of 0.3 to 1.4 cases per 100,000 enrollees per year at a cost of 3
to 13 cents per month per employee.
Mr. Speaker, am I going to be told that an employer is going to drop
his health care coverage for an employee for the difference in cost of
3 to 13 cents per month per employee? I think that a lot of employers
would soon have no employees if that were the case.
Furthermore, employees would not need to abandon control, control,
over a group health plan to remain protected under our bill, the bill
that passed the House. Having HMOs or other third parties make claims
decisions as in the case for the vast majority of small businesses, but
then monitoring the third party would preserve your employer control.
If they are not doing a good job, you do not sign them up next year.
An alternative for some self-insured third party administrators would
be to insure their exposure. If third party administrators truly are
not making medical decisions like they all claim, then their risk will
be small and their premiums will be very low.
Mr. Speaker, in addition, the House bipartisan bill delineates in
section 514(e)(2)(B) several employer activities which specifically
will not constitute an exercise of discretionary authority, such as
decisions to include or exclude any specific benefit from the plan;
decisions to provide extra contractual benefits outside the plan;
decisions not to consider the provision of a benefit while an internal
or external review of a claim is being conducted.
Contrary to our opponents' claims, these carve-outs further insulate
employers from State law actions, but I
[[Page H974]]
think a bit of legislative history is interesting here.
Mr. Speaker, first business groups complained that without these
provisions they would not be able to advocate for an employee not being
treated fairly by their HMO. So the gentleman from Georgia (Mr.
Norwood) and I put those exceptions into the bill. Then those same
business groups complained that the exceptions were in the bill. You
just cannot please some people.
Now let us talk about the punitive damages protections in the House
bill. This is another case in point of how you just cannot please some
people. This provision was suggested to me, as a matter of fairness, by
members of the industry. They said if we are going to be bound by the
external review board's decision and if we follow the board's decision,
then we should not be liable for punitive damages, quote/unquote.
Know what? I agreed, and this provision in my original bill was
incorporated into the Norwood-Dingell-Ganske bill. Maybe Heritage does
not think that this provision is significant, but that is not what I
have heard from the industry. Remember, this punitive damages relief
would apply to all health plans under our bill, not just to group
health plans.
While the Heritage paper closes by saying that the bipartisan House
bill would result in, quote, a staggering amount of red tape for
American doctors and patients, unquote, well, Mr. Speaker over 300
patient and professional organizations have endorsed the bipartisan
House bill. Spare them your crocodile tears, please.
The Heritage paper also quotes Professor Alain Enthoven, a health
policy analyst, from his paper, ``Managed Care: What Went Wrong? Can It
Be Fixed?''
Mr. Speaker, the Bipartisan Consensus Managed Care Improvement Act
will go a long way to fixing the problem that Dr. Paul Ellwood, the
father of managed care, expounded on at a Harvard conference last year.
In speaking of the takeover of health care by managed care, Dr. Ellwood
said, quote, ``Market forces will never work to improve health care
quality, nor will voluntary efforts by doctors and health plans. It
does not make any difference how powerful you are or how much you know,
patients can get atrocious care and can do very little about it.''
Remember, this is the originator of the concept of managed care. He
goes on to say, ``I have increasingly felt that we have to shift the
power to the patients. I am mad,'' he said, ``in part because I have
learned that terrible care can happen to anyone.''
Mr. Speaker, the Norwood-Dingell-Ganske bipartisan House bill which
passed this House with 275 bipartisan votes would shift that power to
the patient. I sincerely hope that the conference committee gets the
message.
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