[Congressional Record Volume 146, Number 88 (Tuesday, July 11, 2000)]
[House]
[Pages H5831-H5836]
From the Congressional Record Online through the Government Publishing Office [www.gpo.gov]
MANAGED CARE REFORM
The SPEAKER pro tempore (Mr. Taylor of North Carolina). 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 am going to speak tonight on managed care
reform, HMO reform. About a week or so ago, the Senate had a short
debate and voted on the Nickles amendment, which was the GOP Senate
version of patient protection.
Now, that amendment was given to Members with very short notice
during that debate. I have the full text here. As one can see, it is
quite dense. It consists of 80-some pages of legislative language, and
so it was not easy to read through this so-called patient protection
bill to understand exactly what was in the bill.
Mr. Speaker, I advised several of my Republican Senate colleagues to
be very careful about voting for that bill, unless they had had a
chance to review the specific language, because, as Members of both
sides of the aisle know, the devil is always in the details in terms of
whether a bill is a good bill or bad bill.
Over the last several days, I have had the opportunity to start
reading the Nickles bill from the Senate, and it sadly is deficient in
several areas. I would liken this more as an HMO protection bill rather
than a patient protection bill.
Mr. Speaker, I am going to go into some detail about why that is, but
it is very important for colleagues on both this side of the Capitol,
as well as the other side of the Capitol to understand what is in this
bill, because we passed a strong patient protection bill here on the
floor of the House of Representatives in October of last year, the
Norwood-Dingell-Ganske Bipartisan Consensus Managed Care Reform bill,
and it had significant bipartisan support, not just 1 or 2 Members of
one party, but 68 Republicans supported that bill, despite intense
opposition by the HMO industry. So we have something to compare the
Senate bill to.
As my colleagues on both sides of the aisle know, there has been a
conference going on between the bill that passed the House and the bill
that passed the Senate. I would say that the conference is not over,
neither the Republicans nor the Democrats in the conference have said
that the conference is over, but nothing much is happening now.
I think it is useful to go into some of the details of the Senate
bill. The Senate bill limits many of its patient protections to only
those Americans in self-insured plans. In fact, more than 135 million
Americans would not receive most of the patient protections identified
in the GOP Senate bill, including access to routine OB/GYN care for
women, and pediatric care for children, continuity of care for
terminally-ill patients, patients receiving in-patient and
institutional care, and pregnant patients in their second trimester of
pregnancy.
It would not include specialty care or access to specialty care,
health care professionals for 135 million Americans; 135 million
Americans would not have access to a point-of-service option. We have
dealt with gag clauses that HMOs have put out in Medicare legislation
that passed both the House and the Senate several years ago that
prohibits contractual clauses that HMOs would try to limit the amount
of information that a doctor could tell a patient without getting an
expressed okay from the HMO; that would not be covered for more than
135 million Americans in the Senate bill.
The GOP Senate bill for 135 million Americans would not cover
emergency medical screening exams or stabilization treatment. There are
many different things.
I want to talk for the longest part of this special order about the
Senate GOP plan's biggest fault, and that has to do with the
enforcement provision or the liability provision.
Mr. Speaker, I have here an analysis of the Nickles GOP Senate bill
by Professor Sara Rosenbaum, who is a Harold and Jane Hirsch Professor,
Health Law and Policy at George Washington University; Professor David
Frankford, Professor of Law at Rutgers University; and Professor Rand
Rosenblatt, Professor of Law at Rutgers University School of Law.
I am going to primarily read this analysis. I think it is very
important to get this into the Congressional Record. This is their
analysis. I know Professor Rosenbaum personally. I respect her opinion
and legal expertise a lot. This is how it goes.
By classifying medical treatment injuries as claims denials and
coverage decisions governed by the Employee Retirement Income Security
Act, the
[[Page H5832]]
Senate bill, this is the Senate GOP bill, insulates managed care
companies from medical liability under State law.
Section 231 of the Senate bill, and I have that here, amends ERISA
section 502 to create a new Federal cause of action relating to a
denial of claim for benefits, quote unquote, in the context of prior
authorization.
Now, this is all kind of technical language, but I will try to make
this clear as we go through. The bill defines the term, quote, claim
for benefits as a request for benefits, including requests for benefits
that are subject to authorization of coverage or utilization review, or
for payment, in whole or in part, for an item or a service under a
group health plan or health insurance coverage offered by a health
insurance issuer in connection with a group health plan, end quote.
Thus, the bill would classify prior authorization denials as claims
for benefits that are in turn covered by the new Federal remedy. You
have to remember that Federal remedies under ERISA section 502 preempt
all State law remedies.
This classification in the Senate GOP bill would have profound
effects, particularly in light of the recent Supreme Court decision
Peagram versus Herdrich. As drafted, the Senate bill would preempt
State medical liability law as applied to medical injuries caused by
the wrongful or negligent withholding of necessary treatment by managed
care companies.
The Senate GOP bill thus would reverse the trend in State law which
has been to hold managed care companies accountable for the medical
injuries they cause, just as would be the case for any other health
provider.
In recent years, courts have considered the issue of managed care
relating injuries, have applied medical liability theory and law to
managed care companies in a manner similar to the approach taken in the
case of hospitals. Thus, like hospitals, managed care companies can be
both directly and vicariously liable for medical injuries attributable
to their conduct.
In a managed care context, the most common type of situation in which
medical liability arises tends to involve injuries caused by the
wrongful or negligent withholding of necessary medical treatment;
otherwise known as denials of requests for care.
Now, State legislatures have also begun to enact legislation to
expressly permit medical liability actions against managed care
companies. The best known of these laws is a medical liability
legislation enacted in 1997 by the State of Texas and recently upheld
in relevant part against an ERISA challenge by the United States Court
of Appeals for the 5th Circuit.
My friends and colleagues from both side of the aisle, you should
know that the Senate GOP bill would preclude Texas law. In the case
Peagram versus Herdrich, the Supreme Court implicitly addressed this
question of whether managed care State liability law should cover
companies for the medical injuries they cause.
The court decided that liability issues do not belong in Federal
courts and strongly indicated its view that in its current form ERISA
does not preclude State law actions. It is that decision that the
Senate bill would appear to overturn.
{time} 2030
Mr. Speaker, continuing this legal analysis of the GOP Senate bill,
in the Supreme Court case Pegram, the Supreme Court set up a new
classification system for the types of decisions made by managed care
organizations contracting with Employee Retirement Income Security Act
plans, ERISA plans. The first type of decision, according to the court,
was a peer eligibility decision. In the ERISA context, that constitutes
an act of plan administration and thus represents an exercise of ERISA
fiduciary responsibilities. Remedies for injuries caused by that type
of determination would be addressed under the ERISA law which currently
provides for no remedy other than for the plan to provide the benefit
itself.
But then the Supreme Court dealt with a different type of situation.
The second type of decision is, according to the Supreme Court, a mixed
eligibility decision. While the court's classification system contains
a number of ambiguities, it appears that, in the court's view, the
second class of decision effectively occurs any time that a managed
care company, acting through its physicians, exercises what is called
medical judgment, regarding the appropriateness of treatment.
Such decisions as medical decisions rather than pure eligibility
decisions are not part of the administration of an ERISA plan and thus
not part of ERISA's remedial scheme because, according to the Supreme
Court, in enacting ERISA, Congress did not intend to displace State
medical liability laws.
The court thus strongly indicated that these claims are not preempted
by ERISA and may be brought in State court. In the court's view, these
mixed decisions represent ``a great many, if not most'' of the coverage
decisions that HMOs make.
So what we have is a situation where the GOP Senate bill is actually,
through legislative language, trying to change the Supreme Court's
recent decision, which held that, where one has decisions related to
medical judgment and not pure eligibility, for instance, a plan that
says we are not going to cover liver transplants, that is pretty
straightforward, if a patient needs a liver transplant, but the plan
explicitly in the contract says we do not provide liver transplants,
that is a coverage decision.
But let us say one has a patient like some of the patients I have
taken care of prior to coming to Congress, I was a reconstructive
surgeon, let us say one has a child born with a cleft lip and a cleft
palate, and the plan then says, oh, that is a cosmetic procedure, that
is a medical judgment, the Supreme Court in Pegram versus Herdrich is
saying that, if that HMO's decision results in a neglect injury, they
should be liable according to State law.
But the Senate GOP bill is trying to change that Supreme Court
decision. The Senate bill would appear to reverse Pegram by effectively
classifying all prior authorization determinations as Section 502
decisions without any regard as to whether they are, ``pure'' or
``mixed''.
As a result, State medical liability laws that arguably now reach
mixed decisions apparently would be preempted by the Senate GOP bill,
leaving individual physicians, hospitals, and other health providers as
the sole defendants in a State court when the HMO has actually made the
decision.
Under the complete preemption theory of Section 502, remedies against
managed care companies would now be governed by the new Federal remedy,
which would effectively shield the industry from accountability under
State law.
See, it is not easy to read through this legislative language when
one is given a bill 15 minutes before it appears on the floor. It is
not easy to make these kinds of arguments to understand what the
language is showing when a bill is kept in secret and then brought up
as an amendment on the floor. So that is why we are going through this
tonight in some detail.
The Federal ``remedy'' in the Senate bill would leave Americans
basically with no remedy. If one looks closely at the Senate GOP bill,
the new Federal remedy simply creates the illusion of relief while at
the same time foreclosing other more meaningful approaches to holding
managed care accountable.
Now, here are some specifics as outlined by Professors Rosenbaum and
Frankford and Rosenblatt. This liability provision in the Senate GOP
bill is unclear on the meaning of the term ``denial'' in the context of
claims that are actionable under the new Federal remedy. Were the
remedy to be interpreted by the courts to encompass only outright
denials, many of the worst types of HMO treatment delays would go
unaddressed.
Here is an example. A recent decision from New York, Aetna U.S.
Health Care used a series of appalling tactics to delay making any
decision regarding treatment for an individual with profound mental
illness related problems over 7 months. When the New York
State Department of Insurance finally ordered coverage, it was too
late. The patient died 8 days before Aetna finally entered a favorable
initial determination.
So my colleagues see, the Senate GOP bill says that a negligent
action can only be brought to trial if there is actually a denial. But
what happens
[[Page H5833]]
frequently is that HMOs will string patients out, they will delay and
delay and delay and delay. In this case, for instance, in New York, if
the patient dies before making that denial, then, under the Senate GOP
bill, HMO is not liable. That is a huge loophole.
By focusing only on denial itself and not covering delays, the Senate
GOP bill effectively would incentivize the HMO industry to put patients
through a delay after delay after delay as a strategy for avoiding any
liability.
The Senate GOP bill also bars any actions that challenge the
company's denial of treatment that it asserts to be ``excluded'',
rather than not medically necessary.
I have come to the floor many times to talk about how HMOs will deny
treatment on the basis of it not being medically necessary. That is the
terminology that they will use. Then they will use their own definition
of medical necessity and can do that under Federal law.
But the Senate Republican bill basically creates a loophole that
would encourage companies to classify denials as exclusions rather than
as denials of claims based on a lack of medical necessity.
The irony is that the external review provisions of the Senate bill
seem to permit review of decisions involving analysis of medical facts,
a broader standard of review than a strict medical necessity standard.
But despite this, the remedy would bar any relief for an individual
whose denial is couched in exclusion terms, rather than medical
necessity terms.
Now, I will just have to tell my colleagues that any good HMO
insurance lawyer is going to advise his HMO to draft all denial letters
in a manner that conforms to that limitation on remedies, another big
loophole for the HMOs in the Senate GOP bill.
Here is another one. In the Senate liability provision, in order to
successfully prove a claim, the injured party would have to prove, not
only a negligent denial, a denial that was made by incompetent staff or
using incompetent standards or using insufficient evidence, but would
have to prove that the denial was made in bad faith.
So let us say that this HMO makes this denial and one's son or one's
daughter is injured because of that. Not only does one have to prove
under the Senate GOP bill that it was a negligent decision, one also
has to prove the motives. One is going to have to prove that it was bad
faith. That is a virtually impossible standard to prove, and it is
particularly egregious in light of the fact that plaintiffs cannot even
bring such an action under the Senate bill unless they have gotten a
reversal of the denial at the external review stage.
Even where they have proven that a company wrongfully withheld
treatment, the injured party can recover nothing for their injures
without taking the level of proof far beyond what is needed to win at
the external review stage. Under the Senate GOP bill, virtually all
injuries would go uncompensated.
Here is another problem with the enforcement provision in the Senate
GOP bill. The injured party would be forced to show ``substantial
harm'' defined in the law as loss of life, significant loss of limb or
bodily function, significant disfigurement, or severe chronic pain. But
that definition excludes some of the most insidious injuries, such as a
degeneration in health or functional status or loss of the possibility
of improvement that a patient could face as a result of delayed care,
particularly a child with special health needs.
I almost wonder whether this provision was put into the Senate GOP
bill specifically to address the case Bedrick versus Travelers
Insurance Company. The managed care company cut off almost all physical
and speech therapy for a toddler with cerebral palsy.
The Court of Appeals in one of the most searing decisions ever
entered in a managed care reversal case found that the company had
acted on the basis of no evidence. With what could only be described as
outright prejudice against children with disabilities, the managed care
companies medical director concluded that care for the baby never could
be medically necessary because children with cerebral palsy have no
chance of being normal.
The consequences of facing years without therapy were potentially
profound for that child. Failure to develop mobility, the loss of a
small amount of motion that a child might have had, a small amount of
motion that could make a big difference in terms of a child's function,
and the enormous cost both actual and emotional suffered by the
parents. Arguably, none of those injuries fall into any of the
categories in the Senate GOP so-called patient protection bill.
Here is another problem. The maximum award in the Senate GOP bill
permitted is $350,000, and even that amount is subject to various types
of reductions and offsets. That limitation on recovery can make
securing adequate representation pretty difficult.
To compound that, in order to mount a case involving bad faith denial
of treatment that we have talked about, that is an enormously expensive
proposition. The limitations on recovery are in addition to the fact
that the Senate bill gives Federal courts exclusive jurisdiction over
cases brought under the new provision.
The costs and difficulties associated with litigating a personal
injury claim requiring proof of bad faith would thus be exponentially
increased, and it would make it virtually impossible for injured people
to find attorneys to represent them. The deck is stacked in that Senate
GOP bill against an injured patient.
{time} 2045
I see my colleague from New Jersey. Would he like to enter into this?
Mr. ANDREWS. If the gentleman would yield, let me first begin by
commending him for his tireless advocacy night after night, week after
week, year after year on behalf of health care and patients in our
country.
My friend from Iowa is a physician first and a Member of Congress
second, and I say that as a compliment. He has carried his Hippocratic
oath to the halls of this chamber and he has done so, Mr. Speaker, with
great distinction, and I want to commend him as a Member of the
opposite party, as a Democrat, commending my friend from Iowa, as a
Republican, for his work on this issue.
I was listening to him tonight, Mr. Speaker, and I wanted to just
supplement what he so very ably is saying in two ways, because I too
have read the legal analysis that my friend from Iowa makes reference
to. I am proud that it was produced by, in part by two scholars from my
district, from the Rutgers University School of Law in Camden, New
Jersey, Dean Rand Rosenblatt and Professor David Frankford were among
two of the three authors who did such an outstanding job on that, and
Sara also was fabulous and I do not want to omit her, from George
Washington University.
Let me say, first of all, the remedy that is in the bill in the other
body is a remedy in form only. It would not have the compensatory or
deterrent effect that a real remedy has. And I believe, frankly, it is
designed to be deficient in those ways. It would make people less than
whole. A person who is denied the ability to see an oncologist and
contracts a form of debilitating cancer would not be made whole by the
bill in the other body. A person who is advised that he or she needs a
test and does not get that test and suffers a fatal or debilitating
injury will not be made whole by the bill in the other body. The damage
limitations are arbitrary and capricious.
The second problem is the lack of a deterrent effect. The value of
the real accountability that is in the bill that passed this House
authored by our colleagues, the gentleman from Georgia (Mr. Norwood),
by the gentleman from Michigan (Mr. Dingell), and by the gentleman from
Iowa (Mr. Ganske), the value of that bill is not the lawsuits that
would be brought under it, it is the lawsuits that would never have to
be brought as a result of it because a managed care company making an
arbitrary and unreasonable decision contrary to the best medical
interest of the patient would be held strongly accountable. And when
that managed care company weighs the balance that it has in front of
it, it would more than likely choose the side of granting the care. It
would choose the side of following the duly-given advice of the
professionals who gave the advice in the first place. It would restore
the primacy of the doctor-patient relationship to American medicine.
And that is what this is about.
[[Page H5834]]
The third point that I would make is that we very often hear from the
opponents of the Patient's Bill of Rights and from the supporters of
the Senate ersatz version that our bill would lead to a flood of
litigation; that it would put lawyers in the place that doctors ought
to be. And there is a certain superficial appeal to that argument. I
understand, Mr. Speaker, that Americans do not want the right to sue,
they want the right to the treatment they have paid for and deserve.
But without the right to sue, without the right to hold people
accountable in a meaningful way, that care and treatment is going to
continue to be arbitrarily and unreasonably withheld by the oligarchs
of the managed care industry.
And people are not going to sit and wait for us to do something about
it. Instead, they are already marching to the courthouse door in State
and Federal Courthouses around this country. As a result, we are now
witnessing what I would call a crazy patchwork quilt of legal decisions
all designed to get around this unreasonable barrier that exists in the
present law that says that under the normal law of tort, under the
normal law of responsibility, managed care companies are immune from
that responsibility. So we have theories about unauthorized practice of
medicine, and we have theories about civil racketeering, and we have
theories about unlawful conspiracy, and we have theories about denial
of quality of care.
To those who fear a flood of litigation if the Norwood-Dingell-Ganske
bill becomes law, I would say that that fear is misplaced; that if the
Norwood-Dingell-Ganske bill does not become law, we can be assured that
there will be a flood of litigation by dissatisfied Americans. And
instead of that litigation being predictable, under a clearly
established set of legal rules and principles written in the statute by
us as the duly-elected representatives of the people, instead those
rules will be written on an ad hoc, case-by-case basis by State and
Federal judges around this country. So I would suggest that that is the
flood of litigation that people should most fear.
So I want to thank my friend for yielding his time. I again salute
him for his truly heroic and tireless work on this issue, and I assure
him that the day is coming when his efforts will bear fruit and this
bill will be signed into law.
Mr. GANSKE. Reclaiming my time, but I hope the gentleman will stay
for a few minutes, because some of the things in that Senate GOP bill
relating to the liability provisions are just amazing. Let me just
relate a couple more for the gentleman.
There is a provision in that Senate GOP bill that says that any group
health plan that offers its members the choice of either an insured
benefit or an individual benefit payment to be used by the Member to
buy an individual insurance policy could not be held liable.
What does that mean? That means that any employer could say to an
employee that they have a group health plan that they can join, or they
can be offered a payment to buy their our own health insurance. In that
situation, the HMO and the employer could not be held liable,
specifically by the language in the Senate GOP bill. There would be no
liability.
Now, the problem with that is that, as most people know, as an
individual it is very difficult to go out and purchase our own
insurance. So that what we would have is, we would have every employer
in the country that offers health insurance saying, well, here is an
option for you. You can buy your own insurance. Of course, no one will
do that because they will not find any individual insurance for their
family. But in so doing, then they totally exclude those plans from any
liability for a negligent decision that they would make.
Mr. ANDREWS. If the gentleman will yield, I want to explain the
consequences for what he has just correctly stated for constituents in
my State.
In my State of New Jersey, an individual buying family health
insurance would pay in the neighborhood of $10,000 a year. But the
price that would be offered through the group plan would be
considerably less, probably $6,500 to $7,000 a year picked up by the
employer. So let us say the employer gives the employee a $6,500
voucher toward the purchase of health insurance. The choice that my
constituents would face under this Senate bill that my friend talks
about would be to either have the right to hold the HMO accountable and
pay $3,500 for that privilege, which the constituent clearly would not
have, or not have the right to hold them accountable.
Now, that is like saying to someone that we are going to give
everyone in America the right to buy a Mercedes Benz for $75,000. Nice
right to have in theory, but if a person does not have the money to
afford it, they cannot do it.
Mr. GANSKE. Here are a couple other provisions in the Senate GOP
bill. Remember, this bill made its first appearance in the light of day
about an hour before it was offered on the floor, and it was offered to
the minority about 15 minutes before it was offered. So not much chance
to review the language. And that bill has never had any hearings.
There are a couple of provisions in there that are very significant.
One provision would basically preclude class actions under the new
ERISA remedy in the Senate GOP bill no matter how widespread the
misconduct of the defendant. For example, an HMO might engage in a
practice of systematically denying every request for treatment in order
to push individuals into external review and delay treatment.
They could just do that all the time. They could deny, deny, and push
everybody into an external appeals thing. They could save a lot of
money on the float that way. But under this provision that is in the
Senate bill, even were the defendant pursuing such a strategy as a
matter of design, the way they are setting up their plan, an individual
could not seek any class action relief.
Here is another problem. We know from a case, Humana v. Forsythe,
that the United States Supreme Court held RICO applicable to a managed
care company that has systematically defrauded thousands of health plan
members out of millions of dollars in benefits by systematically lying
to members about the proportional cost of the treatment they were being
required to bear.
This is how it worked. This HMO had gotten discounts from hospitals,
but the hospitals would send the full price bill to the patient. The
patient typically had an 80/20 policy, meaning that the health plan is
supposed to cover 80 percent of the cost and the patient is supposed to
cover 20 percent. So they would get the full price bill from the
hospital and then Humana would tell them that they had to pay 20
percent of that full price bill, even though Humana was only paying a
fraction of the 80 percent because of a discount. In other words, they
were leaving their beneficiaries paying a much higher percentage of the
bill so that they could pay even less than their discounted part.
Well, that was looked at, and the Supreme Court held that Humana was
fraudulently lying to its beneficiaries and ordered a multimillion
dollar settlement. That is a proper use of the RICO statute. Under the
Senate GOP bill, that would be precluded. A patient could not do that.
Mr. ANDREWS. If the gentleman will yield briefly, under the facts as
the gentleman just outlined them, let us say the patient had a $1,000
hospital bill, as legitimately presented, and the HMO only paid $800.
Under the terms of the contract, the patient would be liable for one
quarter of that $800: $200. But the way the bill was being presented to
the patient, the patient would pay $250. Now, $50 is a lot of money to
people, but it is not enough money to retain an attorney and file suit
and pursue the claim.
Those kind of claims only get meaningfully pursued through class
actions. If thousands of people are owed $50, the economic incentive
exists for someone to file suit and pursue the claim. But if a patient
cannot do that through a class action, person after person after person
who is defrauded out of their $50 will never pursue a legal remedy. And
that is another deficiency in the Senate bill.
Mr. GANSKE. Let me just finish in reading the conclusion from
Professors Rosenbaum, Frankford, and Rosenblatt.
[[Page H5835]]
``The central purpose underlying the enactment of Federal patient
protection legislation is to expand protections for the vast majority
of insured Americans whose health benefits are derived from private
nongovernmental employment and who, thus, come within the orbit of
ERISA. Not only would the GOP Senate measure not accomplish this goal,
but, worse, it appears to be little more than a vehicle for protecting
managed care companies from various forms of legal liability under
current law. Viewed in this light, congressional passage of the Senate
GOP bill would be far worse than were Congress to enact no measure at
all.''
Now that is a sad commentary on a bill. But as I have been looking
through the Nickles bill, I can come to almost every page and have
questions about the legislative language.
I will just talk about this one.
{time} 2100
One of the things that we should be able to reach a bipartisan
consensus on is how do you do an external review and should the
external reviewer be independent?
Let us say that an HMO denies care to your child. Your doctor says
the kid needs the care. So you go through an appeals process within the
HMO. The HMO still says, ``No, we're not going to give that care. It
doesn't meet our own definition of medical necessity.'' So you say, I
want an independent review. And let us just say the Senate GOP bill had
become law. Would that reviewer be independent under the Nickles
independent review plan? Looking at the language, it is real
interesting. The language says that the reviewer could consider the
claim under review without deference to determinations made by the
plan. Could consider but not be bound by the definition used by the
plan of medically necessary.
Then the next clause is very important. Notwithstanding the
independent reviewer would have to adhere to the definition used by the
plan or issuer of medically necessary or experimental investigation if
such definition is the same as, one, that which has been adopted
pursuant to State statute or regulation or, two, that which is used for
purposes under titles 18 or 19 of the Social Security Act.
So what does that mean? I looked at this for a while and I wondered,
because in the bill that passed the House, we just say that that
independent reviewer will be able to determine medical necessity
looking at a number of factors and as long as that benefit was not
explicitly excluded in the contract, then the reviewer would be able to
determine medical necessity. But here they have added a couple of
provisos. They say the medical reviewer has to go use the definition of
the plan, what the plan says is medically necessary if that has been
adopted pursuant to a State statute.
Well, I know exactly why that clause was put in there, because a year
or so ago my home State of Iowa was doing some patient protection
legislation, and I have some expertise in this so some of the State
legislators came to me and asked me about some specific language that
had been provided by the insurance industry. In that language very
cleverly they had a provision that basically said medical necessity is
what we define it to be, i.e., what the plan defines it to be. So if
that happens to be what is in State law, then this independent reviewer
cannot do anything except decide whether the plan has followed its own
definition.
Mr. ANDREWS. There is another grave danger here. And, that is, that
the HMOs will certainly take the position that even if there is not an
explicit statutory definition of medical necessity in State law, that
the State laws which permit them to incorporate their insurance
companies carry with them the implicit right of the HMOs to fix by
contract the definition of the terms of their contract. To sort of
unpack that and put it in less legalese, they will take the position
that State laws implicitly give them the right when they organize
themselves to declare what definitions in their contracts mean, that it
is a matter of contract. And I assure you that every HMO worth its salt
will then put a boiler plate clause in their contract that says medical
necessity means whatever we say that it means. So if your child's
pediatrician thinks that it is medically necessary for your child to
have an MRI but the reviewer for the HMO does not think so because the
statistics show that very few 7-year-olds have a tumor problem, the HMO
wins. That is a loophole that is very subtle but very disingenuous and
very dangerous.
Mr. GANSKE. Reclaiming my time, here is another loophole in the
Senate GOP bill. Who gets to select that external reviewer according to
the Republican plan in the Senate? On page 47, the plan gets to select
that, quote, independent reviewer. That certainly was not in the
version that passed the House.
Here is another loophole. Does that independent reviewer, is that in
the House bill a person who has expertise related to that problem? You
betcha. What about in the Senate? Only if a specialist is, quote,
reasonably available would you get, for instance, an orthopedist
reviewing an orthopedic problem. These are just multiple things that
you can go through nearly every page.
Mr. ANDREWS. The gentleman has just very eloquently described what in
sports we call the home field advantage. Imagine if the home football
team got to pick the referees for every game at its stadium without any
consultation with the visitors or with the conference in which they
play. The home team would win a lot of the games. If you were an
external reviewer, external reviewer A has a track record of favoring
the HMO three-quarters of the time and external reviewer B has a track
record of favoring the HMOs one-quarter of the time, and the reviewers
get paid according to the number of reviews that they do and the HMO
gets to pick the reviewer, you can imagine which reviewer is going to
get more work and what message is going to be sent out to the
reviewers. That is a home field advantage if I have ever heard of one
and it renders the Senate external review procedures to be farcical in
my opinion.
Mr. GANSKE. Let me give the gentleman another example from the Senate
GOP bill. The bill contains a prohibition on plans from requesting or
requiring predictive genetic information. An exception, however, allows
plans to request but not require such information for diagnosis,
treatment or payment.
The problem is that the plan can request that information but does
not have to tell the patient that they do not have to give them the
information. See, that is the type of little legislative language
tricks that you can put into a bill.
Here is another one. The Senate GOP bill allows plans to fulfill
their disclosure obligations by providing prospective enrollees with,
quote, summaries, or, quote, descriptions or, quote, statements of
beneficiary rights rather than specifically enumerating those rights
such as in the bill that passed the House.
These are, I think, minor provisions. They are not as important as
the one related to enforceability, the one related to whether that
independent reviewer is actually independent, whether that independent
reviewer, where there is a difference of opinion on whether care should
be provided or not, is competent or knowledgeable in that area. But
there is still, in aggregate, important provisions for those
individuals.
As you pointed out earlier, I believe firmly that the bill that
passed the House, the Norwood-Dingell-Ganske bill because it is written
to actually protect patients and provide them with due process will in
the long run decrease legal activity rather than increase it. It will
prevent the injury from happening which would then require a legal
remedy because it sets up a bona fide real process for dispute
resolution. Unfortunately, we are just not seeing that in the language
as we have gone through the Senate GOP bill.
I am going to provide my colleagues in the next few days with a more
detailed analysis of the Senate GOP bill. I think it needs to be
examined in-depth. I am very hopeful that as this process continues
over the next several months, we will have an opportunity to correct
the deficiencies.
Mr. ANDREWS. If the gentleman will yield one more time, I want to
conclude my remarks by saying that the gentleman is not a member of the
conference committee that is negotiating the final version of this
bill. I am privileged to be a member of that. I suspect
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that the gentleman is not a member of the conference committee because
he holds, as do dozens of his Republican colleagues, the views that he
has expressed tonight. This bill passed the House with 61 percent of
the Members of the House voting for it, a broad bipartisan coalition.
This is not a Republican or Democratic issue. I am hopeful as a
conferee that we will return to the conference table, we will do so
under the scrutiny of the public and the media, that we will discuss
the issues that the gentleman has raised tonight, and that we will
resolve our differences and give the President a bill that he can sign.
I have been on this conference since it initiated in March, and I
said a few weeks ago that someone on the other side said the conference
was sailing right along, and it was sailing right along smoothly and I
said that they had used the wrong nautical analogy, that the conference
was not sailing right along, that it reminded me more of the
legislative equivalent of the Bermuda triangle, that good ideas go into
the conference and are never heard from again. The gentleman has many
good ideas. I commend him again for his good work and look forward to
working with him to make this the law.
Mr. GANSKE. I thank the gentleman for joining me in this special
order tonight. I look forward to working with him and other Members in
a bipartisan fashion on both the House side and the Senate side to
actually get signed into law a real patient protection piece of
legislation.
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