Skip Maine state header navigation

Agencies | Online Services | Help

Skip All Navigation

Maine.gov > PFR Home > Insurance Regulation > Hearing Decision Index > Document 407 : INS 99-14 : Hearing Decision

NON-CONFIDENTIAL


 

 

STATE OF MAINE
DEPARTMENT OF PROFESSIONAL AND FINANCIAL REGULATION
BUREAU OF INSURANCE

IN RE: APPLICATION OF ASSOCIATED HOSPITAL SERVICE OF MAINE, d/b/a BLUE CROSS AND BLUE SHIELD OF MAINE, TO CONVERT TO A STOCK INSURER AND VOLUNTARILY LIQUIDATE AND DISSOLVE )
)
)
)
)
)
)
)
)
 
IN RE: APPLICATION OF ANTHEM HEALTH PLAN OF MAINE, INC.,
TO ACQUIRE THE ASSETS OF ASSOCIATED HOSPITAL SERVICE OF MAINE, d/b/a BLUE CROSS AND BLUE SHIELD OF MAINE, AND RELATED TRANSACTIONS

Docket NO. INS 99-14 (CONSOLIDATED)

)
)
)
)
)
)
)
)
)
)
)
ASSOCIATED HOSPITAL SERVICES OF MAINE D/B/A/ BLUE CROSS BLUE SHIELD OF MAINE’S RESPONSE TO SECOND DISCOVERY REQUEST OF CONSUMERS FOR AFFORDABLE HEALTH CARE

 

 

February 18, 2000

 

 

 

 

 

NON-CONFIDENTIAL


Applicants, Associated Hospital Services of Maine d/b/a/ Blue Cross Blue Shield of Maine ("BCBSME"), hereby responds to the Second Discovery Request of Consumers for Affordable Health Care, dated February 4, 2000, as follows:

The following responses by BCBSME are subject to BCBSME’s claims of attorney client and work product privilege, and to the protections (where indicated) of the Superintendent’s Protective Orders. To the extent that any additional responsive documents are located in the future, BCBSME reserves its rights to object to producing such documents to the extent covered by the attorney-client and or work product privileges.

  1. Please provide all documents related to financial projections developed by or for the applicants since July 13, 1999 that take into account changes in and/or anticipated changes in enrollment.
    Response:

     

     

     

    See Document #’s P 10020 – 10024, P 10026 – 10034, attached to the confidential version of the Comparative Premium Rate Analysis filed by the applicants on November 4, 1999.

    BCBSME is in the process of updating its financial forecasts. The updated forecasts will reflect, among other things, current expectations with respect to the State employees contract, any changes in results or projections as a result of the exit from the market in Maine of Tufts Health Plan of New England, and the current marketplace activity of Harvard/Pilgrim Health Plan. BCBSME expects that it will have this forecast completed by March 1, 2000, and will produce the report at that time.

     

    The information contained in these documents is deemed

    CONFIDENTIAL PURSUANT TO PROTECTIVE ORDER

  2. Please provide all documents related to AN 02051 (Anthem Pro Forma). Please state in detail Anthem’s assumptions in pro forma (AN 02051) for each of the line items (rows) for each of the calendar years (columns).
    Response:

     

    BCBSME references the response of Anthem Insurance Companies to this request, because the request asks for information concerning a document generated by Anthem.
  3. Please explain in detail the factors Anthem considered that would account for a projected loss of over ____ insureds not counting BCBSME’s ASO lives (over ____ counting BCBSME’s ASO lives) between July 1999 and December 1999?
    Response:

     

    BCBSME references the response of Anthem Insurance Companies to this request, because the request asks for information concerning Anthem’s deliberations.
  4. Please provide all documents related to the state employee health insurance contract for calendar year 2000 and beyond. Please provide all documents prepared by or for the applicants related to financial projections regarding this contract. Please describe in detail the total number of insureds that will be covered under that contract, the contract term, the total anticipated premium incurred for the first contract year and all contract provisions that allow for increases during or subsequent to the first contract year.
    Response:

     

     

     

    See Document #’s B11295 – 11325, which includes a summary description and financial portions of the bid submitted by BCBSME for the Maine State Employees Health insurance contract. Because the bid binder contains many pages of information extraneous to any issues in this proceeding, BCBSME has opted not to copy its entire contents in responding to this request, but has included the full table of contents for the binder. The entire bid binder may be viewed at the State Employee Health Commission.

     

    Portions of the information contained in the documents described in Items 1, 3 and 4 below are deemed

    CONFIDENTIAL PURSUANT TO PROTECTIVE ORDER

    See also the following documents, which were provided to the State’s consultant in connection with the State’s review of the BCBSME bid:

    1. Comparative Premium Rate Analysis ( see B 10000 – 10034 previously filed with Superintendent in this proceeding)
    2. 1999 BCBSME year end financial statements (unaudited) (see B 10000 – 10034 )
    3. 1998 BCBSME annual financial statements (see B01949 – 01999 previously provided in discovery in this proceeding
    4. Capital benchmark calculations (see B 11326 – 11327)

     

  5. Please provide all documents prepared by or for the applicants related to grand total enrollment figures, with and without the ASO, for each of the months December 1999, January 2000, and February 2000.
    Response:

     

     

     

    See Document number B11294 reflecting December 1999 and preliminary January 2000 enrollment information. As of the date of this response (February 18, 2000) no such information has been compiled for February 2000.

     

    The information contained in this document is deemed

    CONFIDENTIAL PURSUANT TO PROTECTIVE ORDER.
  6. Please provide all documents related to "rules of thumb" used by the applicants in determining the value of BCBSME. Please include all documents prepared by or for the applicants related to the value of BCBSME on a "per subscriber" or "per insured" basis.
    Response:

     

     

     

    Rather than using "rules of thumb," BCBSME retained the services of Salomon Smith Barney to provide it with advice on the fairness of offers for the company. See the following documents, previously produced, reflecting work performed by Salomon Smith Barney:

    BC 00001 – 00291

    BC 00883 – 00999

    BC 02558 – 02614

    B 01001 – 01390

    B 05409 – 05496

     

    The information contained in these documents is deemed

    CONFIDENTIAL PURSUANT TO PROTECTIVE ORDER

    Pursuant to 24 M.R.S.A. § 2301(9), BCBSME also retained an independent appraisal firm to perform a valuation of BCBSME. See Houlihan Lokey, Valuation Report of BCBSME. September 15, 1999, Exhibit 12 (filed with BCBSME’s application for approval to convert to stock form).

  7. Please provide all documents prepared by or for Anthem related to the valuation of BCBS plans purchased in all other states. Please include all valuations and/or fairness opinions prepared by or for Anthem and/or the purchased BCBS plan including but not limited to all valuations and/or fairness opinions made by investment banks and/or valuation firms.
    Response:

     

    BCBSME references the response of Anthem Insurance Companies to this request, because the request asks for information concerning Anthem’s activities in other states.
  8. Please provide all documents prepared by or for Anthem related to "rules of thumb" used in determining the value of BCBS plans in other states including but not limited to rules of thumb on a "per subscriber" or "per insured" basis.
    Response:

     

    BCBSME references the response of Anthem Insurance Companies to this request, because the request asks for information concerning Anthem’s documents.
  9. Please provide all documents prepared by or for the applicants related to the marketshare that BCBSME presently has and also the marketshare it anticipates having by the end of calendar year 2000. Please provide all documents prepared on or after January 1999 to the present by or for the applicants related to the value and/or benefit(s) that increased marketshare offers or provides to the applicants. Please explain in detail what value or benefit the increased marketshare offers or provides to the applicants.
    Response:

     

     

     

    See Document #’s BC 00093 – 00142 (Situation Assessment, February 1999); and B 04566 – 04727 (BCBSME 1999 business plan).

    These documents were previously produced.

    For further projections, see Document #’s P 10020 – 10024, P 10026 – 10034, attached to the confidential version of the Comparative Premium Rate Analysis filed by the Applicants on November 4, 1999. These documents include projections of BCBSME enrollment, revenues and costs through 2003. As noted in response to Request #1 above, BCBSME expects to provide updated forecasts when they are completed.

    The information contained in these documents is deemed

    CONFIDENTIAL PURSUANT TO PROTECTIVE ORDER.

  10. Please describe on a per subscriber basis the increase in value of BCBSME since signing the Asset Purchase Agreement in July 1999.
    Response:

     

    As of the date of this response, BCBSME does not have reason to believe the pro forma market value of BCBSME once converted to stock form would be any higher than the purchase price reflected in Asset Purchase Agreement.
  11. What percentage of Tufts’ 70,000 insureds in Maine do the applicants project they will obtain by June 30, 2000? If the sale is not approved or the asset purchase agreement terminates prior to closing, what percentage of Tufts’ 70,000 insureds in Maine does BCBSME project it will obtain by June 30, 2000?
    Response:

     

     

     

    BCBSME is in the process of updating its financial forecasts. The updated forecasts will reflect, among other things, current expectations with respect to the State employees contract, any changes in results or projections as a result of the exit from the market in Maine of Tufts Health Plan of New England, and the current marketplace activity of Harvard/Pilgrim Health Plan. BCBSME expects that it will have this forecast completed by March 1, 2000, and will produce the report at that time.
  12. What percentage of Harvard Pilgrims’ 45,000 insureds in Maine do the applicants project they will obtain by June 30, 2000? If the sale is not approved or the asset purchase agreement terminates prior to closing, what percentage of Harvard Pilgrims’ 45,000 insureds in Maine does BCBSME project it will obtain by June 30, 2000?
    Response:

     

     

     

    BCBSME is in the process of updating its financial forecasts. The updated forecasts will reflect, among other things, current expectations with respect to the State employees contract, any changes in results or projections as a result of the exit from the market in Maine of Tufts Health Plan of New England, and the current marketplace activity of Harvard/Pilgrim Health Plan. BCBSME expects that it will have this forecast completed by March 1, 2000, and will produce the report at that time.
  13. Did any financial projection and/or valuation prepared by or for the applicants assume liquidation of Tufts’ Maine subsidiary during calendar year 1999? Please provide all documents relating to all such projections and/or valuations.
    Response: None of the projections prepared to date reflect such an assumption.
  14. Did any financial projection and/or valuation prepared by or for the applicants assume liquidation of Harvard Pilgrims’ Maine subsidiary during calendar year 2000? Please provide all documents relating to all such projections and/or valuations.
    Response: None of the projections prepared to date reflect such an assumption.
  15. Please describe in detail what information was available to the applicants regarding the financial condition of Tufts’ Health Plans of Massachusetts and/or its Maine subsidiary from January 1999 to the present. Please provide all documents prepared by or for the applicants related to the financial condition of Tufts’ Health Plans of Massachusetts and/or its Maine subsidiary.
    Response:

     

     

     

    BCBSME receives a quarterly publication entitled New England HMO Monitor which provides data from publicly available filings made by managed care organizations to state regulatory agencies. BCBSME also had available to it limited portions of the filings of other health insurance companies with the Maine Bureau of Insurance. See Document #’s B 11559 – 11170.
  16. Please describe in detail what information was available to the applicants regarding the financial condition of Harvard Pilgrim Health Care and/or its Maine subsidiary from January 1999 to the present. Please provide all documents prepared by or for the applicants related to the financial condition of Harvard Pilgrim Health Care and/or its Maine subsidiary.
    Response:

     

     

    BCBSME receives a quarterly publication entitled New England HMO Monitor which provides data from publicly available filings made by managed care organizations to state regulatory agencies. BCBSME also had available to it limited portions of the filings of other health insurance companies with the Maine Bureau of Insurance. See Document #’s B 11559 – 11170.
  17. Provide the names of all entities which expressed an interest in purchasing and/or providing surplus notes to and/or providing surplus notes with an option to purchase BCBSME from January 1996 to the present. Please provide all documents related to the terms and conditions of each of these separate proposals from January 1996 to the present.
    Response:

     

     

     

    BC 00001 – 00291

    BC 00883 – 00999

    BC 02558 – 02614

    B 01001 – 01390

    B 05409 – 05496

     

    The information contained in these documents is deemed

    CONFIDENTIAL PURSUANT TO PROTECTIVE ORDER

  18. Identify each provision in the Asset Purchase Agreement that would increase the total consideration paid by Anthem under circumstances in which BCBSME gains marketshare prior to the closing date beyond that incorporated in the Asset Purchase Agreement. If no provisions were made, why not? How much do the applicants anticipate the value of BCBSME will increase between July 1999 and July 2000?
    Response:

     

    The information contained in this response is deemed

    CONFIDENTIAL PURSUANT TO PROTECTIVE ORDER.

  19. What share of Maine’s private health insurance market do the applicants anticipate having by December 31, 2001? By December 31, 2002? Please provide the calculations underlying these projections.
    Response:

     

     

     

    See Document #’s P 10020 – 10024, P 10026 – 10034, attached to the confidential version of the Comparative Premium Rate Analysis filed by the Applicants on November 4, 1999. These documents include projections of BCBSME enrollment, revenues and costs through 2003. The projections are expressed as numbers of members or enrollees, rather than market share.

     

    Portions of the information contained in these documents is deemed

    CONFIDENTIAL PURSUANT TO PROTECTIVE ORDER

  20. Please provide all documents related to all changes to the Asset Purchase Agreement agreed to by the applicants since July 13, 1999.
    Response:

     

    See Document #’s P 10042 – 10045 (Amendment to Asset Purchaser Agreement), and B 11555 – 11558 (correspondence regarding Medicare liability insurance). When an insurance commitment to cover any residual Medicare liabilities is procured, the commitment will be provided.
  21. Please describe in detail BCBSME’s decisionmaking process that may or will lower the purchase price by increasing BCBSME ‘s liability for Medicare claims under the Asset Purchase Agreement. Provide all documents prepared by or for BCBSME related to the decision. Please state the expected amount of those liabilities and provide all documents estimating the costs of those potential liabilities.
    Response:

     

     

     

    The Charitable Conversion Plan presented by BCBSME provided that the Foundation would bear any Medicare liabilities of BCBSME, since these were unknown. This would have required the Foundation either to cover such liabilities from its own funds, or procure insurance against the liability from its own funds. The Department of Attorney General modified the Conversion Plan so that the Foundation would not bear unknown Medicare liabilities. This change, without compensating adjustments, would have the effect of reducing the value of the assets to be acquired by Anthem under the Asset Purchase Agreement by the value of the unknown Medicare liabilities. Accordingly, Anthem and BCBSME have determined to revise the Asset Purchase Agreement to provide that Anthem will bear such liabilities, but that the costs of insuring against the liabilities will be paid from the proceeds of sale of the assets. Anthem and BCBSME are in the process of procuring insurance commitments to cover the liability, as contemplated by the Amendment to the Asset Purchase Agreement. See Document #’s P 10042 – 10045 (Amendment to Asset Purchaser Agreement), and B 11555 – 11558 (correspondence regarding Medicare liability insurance). When an insurance commitment to cover any residual Medicare liabilities is procured, the commitment will be provided.
  22. Please provide all documents related to BCBSME’s possible conversion to a domestic for-profit stock insurer with or without making an initial public offering (IPO)? Please provide all documents prepared by or for BCBSME related to all valuations of BCBSME as a domestic for-profit stock insurer with and without making an initial public offering (IPO). If BCBSME did not consider converting to a domestic for-profit stock insurer with and/or without making an initial public offering, state why not.
    Response:

     

    The information contained in this response is deemed

    CONFIDENTIAL PURSUANT TO PROTECTIVE ORDER.

  23. Please provide a detailed explanation of all the methods and/or types of valuations that were proposed and/or considered by the applicants? Describe why each method and/or type of valuation was accepted or rejected as a method for valuation. If any other valuation was performed, please provide all documents related to it.
    Response:

     

     

     

    The methods and valuations considered by BCBSME are set out in the work performed by Salomon Smith Barney and Houlihan Lokey. See Document #’s BC 00191 – 00194; BC 00883 – 00999. and Houlihan Lokey Valuation report, dated September 15, 1999, previously produced as B10987 – 11024.

    The information contained in these documents is deemed

    CONFIDENTIAL PURSUANT TO PROTECTIVE ORDER

    In addition, Houlihan Lokey has advised BCBSME that significant portions of the information contained in these documents is proprietary and confidential to Houlihan Lokey, and accordingly the information contained in these documents is deemed

    CONFIDENTIAL PURSUANT TO PROTECTIVE ORDER

  24. Please provide all documents related to interest by any other BCBS plan in purchasing BCBSME in whole or in part since July 1999.
    Response: BCBSME has no documents of this description.
  25. Please provide all documents related to interest by any carrier, HMO, or insurer as defined by Maine law in purchasing BCBSME in whole or in part since January 1998.
    Response:

     

     

     

    BCBSME has located no such documents of this description other than the following documents previously produced:

    BC 0001 – 00291

    BC 00883 – 00999

    BC 02558 – 02614

    B 01001 – 01390

    B 05409 – 05496

     

    The information contained in these documents is deemed

    CONFIDENTIAL PURSUANT TO PROTECTIVE ORDER

  26. Please provide all documents related to all investments made by BCBSME from January 1997 to the present. Please describe in detail the monetary value of those investments and the interest or earnings on those investments in each calendar year from January 1997 to the present.
    Response:

     

    Balance sheets provided by BCBSME in discovery and in the filing summarize the value of investments at various periods, and related income statements summarize investment income from those assets.
  27. Please describe in detail the enrollment efforts made by the applicants in Maine from January 1999 to the present. Provide all documents related to the applicants enrollment efforts in Maine for that time period.
    Response:

     

     

     

    Understanding from a conference with the Consumer Intervenors’ counsel that this request is addressed to efforts by BCBSME to accommodate requests for enrollment at BCBSME following the announcement of Tufts Health Plan’s withdrawal from the Maine Market, BCBSME replies as follows:

    BCBSME made a concerted effort to sell its services, and those of MPHP and CMPHP, to groups insured by Tufts Health Plan of New England. Quoting activity and sales were robust prior to the time in November1999, when Tufts Health Plan of New England was placed under the control of the New Hampshire Department of Insurance. During the first twenty four hours following that event, BCBSME received more than 1,000 requests for quotes from brokers and agents representing Tufts’ clients. BCBSME continued to accept requests for quotes for coverage effective January 1, 2000 or January 15, 2000 until December 13, 1999, at which time it advised its sales staff, brokers, and agents that all subsequent requests for quotes would have to be for an effective date of February 1, 2000. BCBSME allowed cases quoted for January 1, 2000 and January 15, 2000 effective dates to be submitted for coverage by the end of the first subsequent work day.

  28. Please describe in detail the distinctions that Anthem makes between "medical director support", "medical policy", "medical decisionmaking", "medical care management." Which, if any, of these will be performed in Maine by currently employed BCBSME employees? Please provide a chart which describes the positions responsible for each of these items and where (by state) these positions are located.
    Response:

     

    BCBSME references the response of Anthem Insurance Companies to this request, because the request asks for information concerning Anthem’s understanding of certain terms.
  29. Regarding AN 03052 – AN 03058, please describe in detail how long it took to resolve the complaint(s) from the first notice of complaint received by Anthem and the ultimate resolution of the complaint, the personnel involved in resolving such complaint(s) and in which state(s) they are/were based, any payment standard applied in resolution of the complaint(s), and the reason for the length of time taken to resolve such complaint(s).
    Response:

     

    BCBSME references the response of Anthem Insurance Companies to this request, because the request asks for information concerning Anthem’s practices.
  30. During the public hearings, Robert Gibbons, executive director for the Maine Education Association Benefits Trust, stated six (6) conditions that the association wants placed on the purchase. Please provide response by the applicants to each of the six conditions. Mr. Gibbons also stated that the applicants will include certain of the conditions he mentioned in their upcoming contract renewal. Please describe in detail which of the six conditions will be incorporated into the contract and the reasons for such incorporation.
    Response:

     

    The comments of Mr. Gibbons referred to proposed terms of the Bureau’s approval of Anthem’s application under 24-A M.R.S.A. § 222. There have been no discussions between representatives of the MEABT and BCBSME regarding the incorporation of similar provisions in the contract.
  31. Please describe in detail Anthem’s policy rider which delays access to FDA approved prescription drugs for six months and the decisionmaking process used to apply or waive it. Please state in your response who made the decision to impose this rider and where (by state) the such decision was made. Please also include in your response what level of personnel has authority to waive application of the rider and under what circumstances.
    Response:

     

    BCBSME references the response of Anthem Insurance Companies to this request, because the request asks for information concerning Anthem’s operation policies.
  32. Please describe in detail the method Anthem used in collecting and/or providing information regarding prior authorization denials in Connecticut for the November 1998 report issued by the Connecticut Department of Insurance. Please include in your response how Anthem’s methods may have resulted in a higher level of denials than other carriers or HMOs.
    Response:

     

    BCBSME references the response of Anthem Insurance Companies to this request, because the request asks for information concerning Anthem’s activities in Connecticut.
  33. During the public hearings, James Parker, chief of public affairs for Anthem, stated that "All health care is local." Yet, he proceeded to describe a limited number of areas in which health care, especially health care decisionmaking, would remain local. Please state in detail which aspects of health care will not be local or under local control post-acquisition.
    Response:

     

    BCBSME references the response of Anthem Insurance Companies to this request, because the request asks for information concerning Anthem’s activities following the acquisition of the assets of BCBSME pursuant to the Asset Purchase Agreement.
  34. Provide all documents related to utilization review criteria used by Anthem that will differ from BCBSME’s current utilization review criteria by product.
    Response:

     

    BCBSME references the response of Anthem Insurance Companies to this request, because the request asks for information concerning Anthem’s intentions following the acquisition of the assets of BCBSME pursuant to the Asset Purchase Agreement.
  35. Please describe in detail the changes in utilization review criteria that Anthem has imposed subsequent to each BCBS plan from January 1995 to the present. Provide all documents related to changes to utilization review criteria in each state where Anthem purchased a BCBS plan from January 1995 to the present.
    Response:

     

    BCBSME references the response of Anthem Insurance Companies to this request, because the request asks for information concerning Anthem’s activities in other states.
  36. Please describe in detail BCBSME’s subsidies for insured’s premiums, copayments, coinsurance, or deductibles past or present. Please state in detail eligibility criteria for such subsidies.
    Response: BCBSME has not provided such subsidies for at least the last 3 years.
  37. Please describe how Anthem will outline and/or inform its subscribers about reproductive health services. Please include in your response all reproductive health services Anthem will cover.
    Response:

     

    BCBSME references the response of Anthem Insurance Companies to this request, because the request asks for information concerning Anthem’s intentions following the acquisition of the assets of BCBSME pursuant to the Asset Purchase Agreement.
  38. Will Anthem contract with family planning programs for all the services each program currently provides including but not limited to colposcopy and endometrial biopses? Please provide the rationale for your response.
    Response:

     

    BCBSME references the response of Anthem Insurance Companies to this request, because the request asks for information concerning Anthem’s intentions following the acquisition of the assets of BCBSME pursuant to the Asset Purchase Agreement.
  39. Will Anthem contract with nurse practitioners in Maine?
    Response:

     

    BCBSME references the response of Anthem Insurance Companies to this request, because the request asks for information concerning Anthem’s intentions following the acquisition of the assets of BCBSME pursuant to the Asset Purchase Agreement.
  40. Will Anthem allow its insureds in Maine to self-refer to reproductive health providers (including but not limited to nurse practitioners) beyond the state-mandated statute of one annual visit a year? Please provide the rationale for your response.
    Response:

     

    BCBSME references the response of Anthem Insurance Companies to this request, because the request asks for information concerning Anthem’s intentions following the acquisition of the assets of BCBSME pursuant to the Asset Purchase Agreement.
  41. Please describe in detail what the term "IBNR" includes as used by BCBSME.
    Response:

     

     

    As used by BCBSME, the term "IBNR" includes the company’s expected liability for claims that have been incurred (i.e., a covered service has been rendered to a member by an eligible provider) but not yet paid, either because they have not yet been submitted or because they are in the process of being paid.
  42. Please describe in detail the procedures that are currently utilized by Anthem to ensure confidentiality of insureds’ records and to ensure that access to insureds’ records is restricted. Please include in your response the names of all companies, including but not limited to pharmaceutical, brokerage and telemarketing firms, with whom Anthem shares any insured information on a confidential, redacted or non-confidential basis.
    Response:

     

    BCBSME references the response of Anthem Insurance Companies to this request, because the request asks for information concerning Anthem’s operational practices.
  43. Please describe in detail the procedures that the applicants’ will use to ensure confidentiality of insureds’ records and to ensure that access to insureds’ records is restricted? Please state whether Anthem anticipates making insureds’ records available to any entity on any basis. If yes, please describe in detail what information, the uses for which it would be made available, and the bases upon which it would be provided.
    Response:

     

    BCBSME references the response of Anthem Insurance Companies to this request, because the request asks for information concerning Anthem’s intentions following the acquisition of the assets of BCBSME pursuant to the Asset Purchase Agreement.

DATED: February 18, 2000

________________________

Robert S. Frank

HARVEY & FRANK

Two City Center

Suite 402

Portland, Maine 04112-0126

(207) 775-1300

Attorneys for Associated Hospital Services of Maine d/b/a/ Blue Cross Blue Shield of Maine

 

 

Last Updated: August 22, 2012