STATE OF MAINE
DEPARTMENT OF PROFESSIONAL AND FINANCIAL REGULATION
BUREAU OF INSURANCE
| IN RE: |
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| Application of Associated Hospital Service |
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| of Maine d/b/a Blue Cross and Blue Shield |
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| of Maine to Convert to a Stock Insurer |
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| and Voluntarily Liquidate and Dissolve |
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SECOND DISCOVERY REQUEST |
| and |
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OF THE ATTORNEY GENERAL |
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| IN RE: |
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| Application of Anthem Health Plan of |
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| Maine, Inc. to Acquire the Assets of |
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| Associated Hospital Service of Maine d/b/a |
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| Blue Cross and Blue Shield of Maine and |
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| Related Transactions |
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| Docket No. INS-99-14 |
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| (Consolidated) |
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TO: Associated Hospital Service of Maine
c/o Robert Frank, Esq.
Harvey and Frank
Two City Center
P.O. Box 126
Portland, Maine 04112-0126
Anthem Health Plan of Maine, Inc.
c/o James Zimpritch, Esq.
Pierce Atwood
One Monument Square
Portland, Maine 04101-1110
The Attorney General requests that you provide responses to the following inquiries and
document requests. In producing the requested documents, the Applicants are requested to
furnish all documents regardless of whether they are in the possession of Associated
Hospital Service, Anthem Health Plan of Maine, or any subsidiary, affiliate, or parent of
either entity. If the Applicants refuse for any reason to provide any of the documents
described below, the Applicants should identify in writing each such document and provide
the reason for such refusal.
Definitions:
- "Anthem" means Anthem Insurance Companies, Inc., Anthem East, Inc., Anthem
Health Plans of Maine and any subsidiary, affiliate or parent of such entities.
- "BCBSME" means Associated Hospital Service of Maine and any subsidiary,
affiliate or parent of such entity.
Requests
- Please provide a copy of all documents submitted by Houlihan Lokey Howard and Zukin
Financial Advisors, Inc. ("Houlihan Lokey") to BCBSME related to Houlihan
Lokey’s performance of the valuation of BCBSME, including without limitation all
information concerning Houlihan Lokey’s relevant experience and expertise and all
proposals.
- Please provide a copy of the engagement letter and any other documents related to
the retention of Houlihan Lokey by BCBSME to perform the valuation.
- Document B 00071 lists Houlihan Lokey’s valuation opinion engagements. This
list does not include any valuation opinion for the health services industry. Please
describe in detail the experience of Houlihan Lokey in doing valuation opinions of a
health maintenance organization or other health services organization.
- Please state whether Houlihan Lokey has ever served as a consultant to Anthem. If
your answer is "yes," please identify the company and explain in detail the
nature of the work.
- 5. Please state whether Houlihan Lokey has ever served as a consultant to BCBSME or any
other Blue Cross Blue Shield company. If your answer is "yes," please identify
the company and explain in detail the nature of the work.
- 6. Please describe in detail any contingency plans of BCBSME if the application of
Anthem to purchase the assets of BCBSME is not approved by the Superintendent or the asset
purchase agreement as terminated prior to closing. Please provide all documents related to
such contingency planning.
- 7. For each state in which Anthem conducts health insurance business, please provide
all documents related to any complaint index maintained by such states. Include in your
response an explanation of how the complaint index was calculated.
- 8. Please state whether Anthem, or any health insurance subsidiary or affiliate of
Anthem maintains a log of customer complaints. If your answer is "yes," please
identify the company(ies) and produce the logs for the period January 1, 1997 to present.
- 9. For each Anthem health insurance subsidiary or affiliate, please produce all
documents for the period January 1, 1997 to the present, related to any policyholder
complaints filed with state regulators, including without limitation, complaints regarding
claims processing and payment.
- 10. Please state whether the NAIC has initiated any enforcement actions against Anthem
or any health insurance subsidiary or affiliate of Anthem during the period January 1,
1997 to the present. If your answer is "yes," please produce all documents
related to each such action.
- 11. Please state whether Anthem or any health insurance subsidiary or affiliate of
Anthem has conducted internally, or retained a consultant to conduct, an examination or
evaluation of claims handling and payment procedures and practices.
- 12. If the answer to Request No. 11 is "yes," please provide a copy of any
findings, reports, and recommendations resulting from the examination or evaluation.
- 13. With regard to Request No. 11, please describe, and produce any documents related
to, action taken in response to any recommendations.
- 14. To the extent not provided in response to Request No. 6 in the First Discovery
Request of the Attorney General, please provide a copy of any market conduct examination
of any Anthem health insurance subsidiary or affiliate.
- 15. Please provide a copy of any internal audits performed by, or for, Anthem or any
health insurance subsidiary or affiliate during the period January 1, 1997 to present. In
addition, please provide a copy of any management responses.
- 16. With regard to Anthem and any health insurance subsidiary or affiliate, please
provide copies of any correspondence from or to state regulating authorities regarding any
significant financial or operational issues for the period January 1, 1997 to present.
Dated: January 11, 2000
_____________________________
WILLIAM H. LAUBENSTEIN, III
Assistant Attorney General
6 State House Station
Augusta, ME 04333-0006
Telephone: (207) 626-8800
