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Maine.gov > PFR Home > Insurance Regulation> Administrative & Enforcement Actions > Document 618 : INS 99-14 : Hearing Decision
STATE OF MAINE
NOW COMES Intervenor, MHA, Inc. (MHA), through its undersigned counsel, and submits this Prefiled Testimony of Dana Kempton, Associate Director of Redington-Fairview General Hospital, consistent with the terms of the Superintendents Procedural Order of November 4, 2000.
Q: Please identify yourself and your place of employment.
A: Dana Kempton, Associate Director of Redington-Fairview General Hospital, P.O. Box 468, Skowhegan, Maine 04976.
Q: Please provide a brief summary of your educational background and employment history.
A: I am a native of Auburn, Maine. I received a B.A. in Political Science from the University of Maine in Orono in 1972 and a Master of Science in Accounting from Northeastern University in 1976. I worked at Arthur Young & Co. from 1976 to 1978, Redington-Fairview General Hospital from 1978 to 1985 as Director of Finance, Exeter Health Resources, Inc. Exeter N.H. as Senior Vice-President of Finance from 1985 to 1991 and left there to assume my current position at Redington-Fairview General Hospital.
Q: How significant is Blue Cross Blue Shield of Maine (BCBSME) to your Hospital?
A: Blue Cross represents the single largest nongovernmental payor at Redington-Fairview General Hospital. Over the past three fiscal years, these payments averaged 13.1% of all payments received by our Hospital and 32.6% of all non-governmental payments. Since the Hospital is paid less than its costs from the Medicare program, which has averaged 49.5% of its revenues over that same timeframe, Blue Cross represents a critical source of payment to the Hospital. These payments can be summarized as follows:
As the chart illustrates, Blue Crosss share of our market will increase dramatically as a result of Tufts leaving the Maine market. For example, Redington-Fairview General Hospitals own employer-sponsored health plan has returned to Blue Cross Blue Shield following the demise of Tufts.
Q: Could you comment on the significance of BCBSME to the physicians who practice at your hospital?
A: Certainly, from discussions I have had with office managers at the two largest primary care groups in Somerset County and my own observations of the marketplace, I would estimate that their percentage of Blue Cross business would mirror the Hospitals.
Q: Are you familiar with the Standards and Requirements sought by the MHA in the Anthem proceedings?
A: Yes. I am a member of the MHAs Council on Economics and Finance (CEF) and chaired this body from October 1997 until January 2000. I was in attendance at the meeting where the MHA CEF framed its recommendations for these Standards and Requirements. Upon review by the MHA Council on Health Policy, these recommendations formed the MHAs Standards and Requirements.
Q: What were some of the concerns of you and other members of the CEF reviewed as you considered appropriate Standards and Requirements?
A: In light of several recent events, my colleagues and I have been, and continue to be, greatly concerned about the financial integrity of Maines health insurers, managed care organizations, and particularly its HMOs. These concerns have grown over the past several months, with the financial difficulties faced by Tufts Health Plan and by Harvard Pilgrim Health Care, among others. For some time, we have been gathering figures of the exposure faced by Maine hospitals. Our concern arises from a number of factors:
* American Hospital Association Hospital Statistics 2000
** Geospatial and Statistical Data Center maintained by the University of Virginia, www.fisher.lib.virginia.edu
As can be seen from the chart, Maine is a large, sparsely populated state dominated by small rural hospitals and, therefore, is very different from the other states where Anthem had previously done business.
Q: Could you comment on the exposure faced by the Redington-Fairview General Hospital from the Tufts insolvency?
A: Currently, we have $ 190,000 in past due payments to the Hospital. Based on discussions I have had with physician practice managers in the community, I would expect that an equal amount would be due the physicians from our community.
Q: What are the prospects of recovery?
A: The proceedings before the New Hampshire Commissioner of Insurance has required payment only for bills rendered subsequent to December 20, 1999. We are totally exposed for payments prior to that date. We are not optimistic that we will recover these amounts.
Q: What have been your observations regarding the New Hampshire proceedings governing Tufts?
A: I have been troubled by having to rely upon the New Hampshire Department of Insurance as the governmental entity carrying out these proceedings. I understand that Superintendent Iuppa and the Maine Bureau of Insurance (BOI) have monitored these proceedings closely and have kept our Association posted. I would have had more confidence, however, if our Maine BOI had been directly involved in the running of these proceedings.
We attended the creditors meeting in Portsmouth and were quite astounded to find that the administrative costs from the bankruptcy/insolvency proceedings alone totaled $8 million. Absent the bankruptcy, these resources would have been available to pay claims. Under the supervised insolvency proceedings, these administrative costs must be paid before the claims of providers. The entire bankruptcy and cessation of business by Tufts of New England has been an education to my staff. We have found that, now that TNE is ceasing to do future business in Maine or New Hampshire, it no longer has any business reason to process claims promptly. As many other hospitals have discovered, claims are being "pended" or denied in most cases. My staff has to rebill claims continually in order to have TNE recognize these claims as legitimate.
Once accepted, these claims will have to be perfected with the bankruptcy court. The whole process is a nightmare for the providers, with the end result being that we will probably be paid 25 to 50 cents on the dollar.
Q: Do you have an understanding of the reasons why the New Hampshire Department has had primary responsibility?
A: Yes. It is my understanding that activities of Tufts Health Plan in Maine have been carried out through a New Hampshire domiciled corporation, and not a Maine domiciled corporation.
Q: Are you familiar with the First Standard and Requirement sought by the MHA?
A: Yes. This Standard and Requirement is Require That Anthem Blue Cross Blue Shield Be A Corporation Domiciled In Maine, Both Initially And Permanently Thereafter.
Q: Could you comment on the significance of this condition from the perspective of your Hospital?
A: Yes. Given the importance of Blue Cross, I believe this condition is one of the many lessons that this State should learn from the Tufts failure. I believe that, in order to protect the consumers and providers of this state, the requirement that Anthem Blue Cross Blue Shield be a corporation domiciled in Maine permanently is critical. Furthermore, this requirement will assure that the Maine BOI will directly regulate Anthem/Blue Cross on an ongoing basis. Then, in the event there is any rehabilitation, insolvency or other proceedings, these will be under the direct jurisdiction and supervision of the Maine Superintendent. Otherwise we may find ourselves traveling to Indiana for a bankruptcy hearing.
Q: Why is this important to you?
A: It is critically important in the context of the Blue Cross Plan. As I have stated earlier, this currently constitutes 45% of our Hospital and physician payments. Likewise, BOI figures noted earlier give Blue Cross a 47% market share for 1998. We cannot afford to have another state regulating these essential activities.
Q: Are you familiar with the second Standard and Requirement sought by the MHA?
A: Yes. This is to Require Anthem Parent To Guarantee Satisfactory Performance Of All Insurance And Provider Contracts And Other Obligations Of Anthem Blue Cross Blue Shield.
Q: Why is this important to you and your Hospital?
A: I repeat many of the reasons I cited on the first Standard and Requirement. Based upon the Tufts experience, we are not comfortable in relying solely upon the current resources available to the Maine corporation.
It is important to remember that BCBSME is a non-profit corporation which, when it ceases to do business as an ongoing entity, is required under Maine law to transfer the value of its charitable assets to a charitable trust. The successor Maine Anthem/Blue Cross corporation will be the subsidiary of a national Anthem parent. Due to this change in structure, the local Anthem entity has the opportunity to transfer funds to its parent, and will not be subject to the provisions of Maine law governing Maine charities or the special provisions of law applicable to the existing Maine Blue Cross Plan.
We have also understood that a principal reason for the sale of Blue Cross to Anthem is to provide capital to Blue Cross of Maine. If the purchase does not contain an unconditional guarantee by the parent of Blue Cross of Maine, then one needs to question how the sale of Blue Cross of Maine will guarantee the availability of necessary capital. Second, if we do not make this requirement, then we have not learned another valuable lesson from the Tufts failure. The failure resulted from a vote by the parent company to stop funding the subsidiarys losses. We were fortunate that Tufts had not captured a larger percentage of the healthcare market. What would have happened if the bankruptcy involved Blue Cross and 47% of the consumers? I think we only need to look at the proceedings and concern generated by the financial situation of Harvard/Pilgrim for some insight. Clearly, the State of Massachusetts was concerned that the insolvency of Harvard/Pilgrim could bankrupt large portions of its entire healthcare system. Furthermore, what would have been the response if, in addition to that pressure, the proceedings and decision-making were being made in Indiana, as opposed to Maine?
These factors point to the need to adopt both MHA Standard One, a Maine domiciled corporation, and Standard Two, a parental guarantee.
In order to protect both consumers and providers, we think it is both prudent and appropriate that the parent be required to guarantee the performance of the Maine corporation.
Q: Are you familiar with the third Standard and Requirement sought by MHA?
A: Yes. It would Prohibit Or Limit Anthem Ability To Upstream Or Transfer Maine Resources To Other States.
Q: Could you explain your reasons for seeking this requirement?
A: Again, many of the prior reasons are applicable here, as well. Because BCBSME is a free-standing Maine based corporation, all of its assets remain available to satisfy its obligations. Anthem, with a national based parent, has the potential for transferring significant assets out of state.
Q: What limitations do you view as appropriate in this context?
A: Clearly, if the State requires the parent to guarantee the operations of the subsidiary, then the parent should be allowed to take a percentage of its profits from the State as a return on its investment. On the other hand, the consumers and providers of the State need to be protected from the transfer of a significant portion of the assets of Blue Cross out of Maine , which could then subsequently jeopardize its operations. I would suggest that the amount of profit transferred out of the State be limited to a reasonable return on its investment. I recall that the Maine Health Care Finance Commission recognized a standard rate of a Treasury Bill return, plus two percent. This would be a reasonable standard to use here as well.
Q: Are you aware that the third Standard has been deemed "irrelevant" by the Superintendent?
A: I was disappointed and distressed to learn this this ruling makes all the more important that the remaining MHA Standards and Requirements be adopted.
Q: Are you familiar with the fourth Standard and Requirement sought by MHA?
A: It is to Require Anthem to Continue Distinct Contracts with Distinct Providers.
Q: Could you explain this Standard and Requirement further?
A: We seek to require that Anthem obtain absolutely separate provider contracts with each distinct economic unit. For example, if a radiology group that is the designated provider of such services for a particular hospital declines to sign an Anthem contract, MHA seeks to assure that Anthem cannot impose upon the hospital contractual provisions that dock the hospital a percentage of its payment in order to cover Anthems incremental costs of paying the radiologists as out-of-network providers. All contracting should be on an arms length basis that respects the separation of these distinct entities.
Q: Do you have any evidence of information to suggest that Anthem or other payors engaged in these practices?
A: We have run into situations where other payors have discussed with the Hospital a methodology whereby the Hospital would have a capitated payment which would include various hospital-based physician services, including, for example, radiology, anesthesiology, pathology and so on.
These so-called hospital-based physicians do have contracts with the Hospital to provide, on an exclusive basis, these services. This fosters quality control and permits the Hospital to provide these important services on an efficient and timely basis, 24-hours a day.
Payors have not always been able to obtain agreement from these physician groups for these capitated rates or for their proposed fee schedule. Since the physician groups are independent contractors who are free to accept or reject any prices offered, we as hospitals are not able to control their behavior from an economic standpoint. Furthermore, given our location, size and Medicare/Medicaid mix, physician recruitment is an ongoing and difficult undertaking despite Skowhegans designation as a Federal Health Professional Shortage Area. The recruitment and retention of physicians is ongoing and difficult, particularly given our high percentage of Medicare and Medicaid recipients.
Given the disparity in size between Blue Cross and institutions similar in size to Redington-Fairview General Hospital, we fear that a new Blue Cross under Anthem control could force an unfair financial arrangement. We do not have a problem with negotiating with payors for the portion of services that the Hospital controls and can deliver on its own. We do have a significant problem if we are required by payors to take a hit, to the extent physician groups are not willing to agree to accept the price offered by the payor for their piece of the service provided.
Q: Do you have heightened concerns on this issue in the context of the Blue Cross plan?
A: Certainly. In the case of a payor with a 45% share of our market, we are especially concerned that it not use its market power to extract terms we believe to be unfair, or to saddle the Hospital with the responsibility of "eating" perceived losses from this high-share insurer.
Q: Are you aware that the fourth Standard has also been deemed "irrelevant" by the Superintendent?
A: I do not understand the basis for this ruling and hope the Superintendent reconsiders the ruling and adopts this fourth Standard.
Q: Are you familiar with the fifth Standard and Requirement of MHA?
A: Yes. This is to Require Anthem to Continue Certain Other Provider Contracting Practices of BCBSME.
Q: Could you list the first requirement?
A: We seek to require Anthem to continue Blue Cross Blue Shields practice of providing periodic interim payments (PIP) consistent with the timing and methodology historically utilized by Blue Cross Blue Shield.
Q: What has been the practice of BCBSME for PIP payments?
A: BCBSME has made periodic interim payments every week based upon a projection methodology that looks at our claims history and projected claims. For example, last fiscal year payments totaled $ 2,779,000, or $ 53,453 received weekly.
Q: Why has this been important to your Hospital?
A: As I stated previously, many hospitals rely upon these PIP amounts to continue operations. These weekly amounts are a reliable and stable source of cash. At small institutions, the turnover of a single key individual can result in delays in billing. For example, in medical records, personnel are specifically trained in coding the diagnoses associated with the services performed for the patient. These codes must be completed in order to bill and collect for those services. The departure of a single coder can cause a backlog in the filing of claims until new personnel are hired and trained. With the PIP system instituted by Blue Cross of Maine, these situations are not compounded with the burden of seeking financing in order to have cash to pay for operating expenses such as payroll.
Q: What is the second practice you seek to have Anthem continue?
A: We seek to require that Anthem follow Maine Blue Cross Blue Shields established procedures for defining, processing and paying "clean claims." To date, Blue Cross and Blue Shield has built an outstanding system for the prompt payment and accurate processing of claims. Blue Cross is virtually the only non-governmental payor where we do not have problems with bills not being paid promptly. I would also like to point out the relationship between PIP and the prompt processing of claims. Since Blue Cross sends a weekly amount to hospitals, they do not have the same financial incentive to hold claims that other payors do.
Q: How is Blue Crosss definition of "clean claims" different from other payors?
A: As I pointed out, Blue Cross does not have any financial incentive to withhold payment. Consequently, they have been more reasonable on a number of fronts. Blue Cross does not have numerous unique billing requirements such as bundling some services into one line item while other items are allowed to be billed as unbundled charges. Blue Cross has not attempted to reduce payment through utilization review, as have other payors. We have not had to refer Blue Cross patients to the Bureau of Insurance as a result of the nonpayment of services as we have with other payors. For example, we have referred numerous consumers to the Bureau of Insurance with issues involving CIGNA/Healthsource. Blue Cross has not attempted to institute an unworkable referral system for primary care physicians (PCP) as did Aetna/U.S.Healthcare upon their entry to the Maine market. In this instance, Aetna/U.S. healthcare discontinued its referral system when PCPs refused to sign participating agreements. Blue Cross currently enjoys an excellent reputation in the provider community which is unmatched by any other payor.
Q: What impact does this have on you?
A: We have had to increase our billing staff. We have had to dedicate valuable programming time to accommodate the unique billing rules of other payors. We have had to direct consumers to complain to either the company, in the case of employer-sponsored health plans, or to the Bureau of Insurance or both. We have had to appeal cases through the utilization review process of the insurance carriers, thereby again expending valuable resources. My medical records and billing staff generally are starting to view the majority of payors as being dishonest. Consequently, their stress level is high.
Q: What is the third prong of Blue Crosss practice you seek to have continued?
A: We seek to require that Anthem continue Maine Blue Cross Blue Shields practice of maintaining a statewide network of providers consistent with historic levels of participation.
Q: Please explain the reasons you think this requirement is important.
A: Maine Blue Cross Blue Shield has historically maintained a very extensive network, and to my knowledge, more extensive than that of other payors. My colleagues and I on the MHA CEF are concerned that Anthem management, headquartered in Indiana, while supervising the entire eastern region, may frankly be less concerned about the extent and quality of health care in the far reaches of Maine than was the case with Maine Blue Cross, headquartered in South Portland. We noted with concern that the Anthem September 15 Form A filing stated Anthem would consider "selective contracting" in portions of Maine. We are concerned about the potential for "selective contracting" where Anthem might choose to contract with some hospitals but not others in an effort to extract greater price concessions or lower administrative costs. We note that this particular standard has also been deemed irrelevant and I urge the Superintendent to reconsider his position on this as well.
Q: Could you describe the potential impact on your Hospital if these practices are not continued?
A: When the Hospital and the physicians on its medical staff are not made a part of a new carriers network, typically a great deal of confusion occurs for the consumer. Generally, the consumer is not aware that they purchased insurance that might require them to travel to Bangor, Waterville or Augusta for treatment and services. Consequently, they receive treatment at our Hospital. They are extremely angry when they find that they have to pay expenses out of their own pocket. In the case of employers, we have had situations where the employer has decided not to change carriers when they discovered their new carrier did not have a contract with the Hospital. However, all my experiences have occurred with new carriers seeking to gain new business. I have not actually experienced a situation where a major payor with an existing contract has decided to terminate their contract with the Hospital. The massive amount of dislocation that would occur among patients and providers is hard to imagine.
Q: Shouldnt the market be permitted to address this question, and isnt there a risk that a regulatory requirement obligating Anthem to maintain a network equivalent to that of Blue Cross might tilt the playing field or the bargaining equation in favor of the Hospitals?
A: We do not believe that is a risk with a payor that has a 47% share of the health insurance market statewide. Our Hospital and our medical staff have a responsibility to serve the employers and patients within our community, many of whom have historically chosen Blue Cross coverage. We are simply seeking to require regulatory oversight by the BOI, so that a large, well-capitalized, dominant payor cannot refuse to deal with a small rural 65-bed hospital , but rather will be required to negotiate in good faith. We are simply trying to protect against a circumstance where Anthem might refuse to deal with us, or otherwise be unreasonable in the negotiation process. Given this situation, we would have to decide between signing a contract with a bad financial arrangement, which might threaten our financial viability or otherwise jeopardize our ability to treat patients in the long-term, or not to not sign such a contract and place our hospital at odds with our community immediately. The two options are not very palatable.
Q: Are you familiar with the sixth Standard and Requirement sought by MHA?
A: Yes. This is to require Anthem to Maintain BCBSME Access and Prevention Initiatives.
Q: Could you provide your perspective on the importance of this requirement?
A: Blue Cross has provided funding in the past for community-based initiatives. For example, in our case, Blue Cross generously helped sponsor an educational consortium on the treatment of cardiac disease. As you may know, the Maine State Health Plan has identified the reduction of cardiac disease as one of its major public health initiatives. As you may not be aware, Somerset County has the highest incidence of cardiac disease in the State. Consequently, the sponsorship of Blue Cross was greatly appreciated. I think that all my testimony to this point has underscored an important point. Blue Cross has been a corporate citizen, honest in its business dealings, attempting to positively impact the health and lives of Maine consumers and providers.
Q: Are you familiar with the eighth Standard and Requirement sought by the MHA?
A: This is to prohibit "Most Favored Nation" requirements in Anthem provider contracts.
Q: Please describe your reasons for seeking to impose this requirement.
A: We understand that in its filings to this point, Anthem has stated it has used "most favored nation clauses" in hospital and institutional contracts in other states. My basic concern is that such a requirement would inhibit and frustrate the innovative contract approaches we have in mind and have discussed with payors and local employers.
If we were required to extend each and every discount or particular contract provision to Anthem, with its 45% plus share in our market, we would be reluctant to experiment with other payors and self-insured employers. For example, Somerset County is a poor county with a high level of uninsured. At one point, Redington-Fairview General Hospital received a demonstration grant, MaineCare, whereby the Hospital discounted its services by 30% to a carrier who developed an insurance product for low income individuals. However, if we had to extend this discount to Blue Cross, we would not have been able to participate in this program. Currently, we are discussing whether the reestablishment of this type of program would help stop the unraveling of the risk pool in Somerset County. A second example involves the fitness club that we recently purchased. We have a local self-insured business that has a high percentage of employees with high cardiac risk factors. We have been thinking about giving them a discount on their health insurance claims if they have a percentage of their employees complete an exhaustive cardiac screening and behavior modification process. One aspect of the behavior modification process might be the purchase of memberships at the Fitness Center. In this manner, we can give an incentive to the employer to implement a wellness program focused on a major public health goal established by the Maine State Health Plan. We have a number of self-insured employers to whom we might want to extend this option. Obviously, if Blue Cross had a most favored nation clause, we would have limited flexibility in our discounting structure in both cases.
Once again, I understand that the Deputy Superintendent has initially ruled pursuit of this standard to be irrelevant in this proceeding. I urge the Superintendent to reconsider this ruling in light of my testimony and that of the other MHA witnesses. Due to the factors I have identified, MFN clauses can have a direct negative impact on the nature and cost of services we can provide to Blue Cross subscribers and other consumers and employers, and should be prohibited on that basis.
Q: Are you familiar with the ninth Standard and Requirement of MHA?
A: Yes. This is to require Anthem to maintain reserve funds in Maine adequate to pay claims and all related provider obligations for at least the time period equivalent to the notice period required to terminate contracts by either party.
Q: Can you explain your reasons for supporting this requirement?
A: Certainly. My reasons are fairly straight-forward. We believe it is fair and just that all payors be required to have sufficient reserves to cover the obligations we are obligated under State law to provide. As noted above, we have had a bad experience with Tufts and others in this regard.
We understand that the current HMO law, Section 4204(8) requires providers to give at least sixty (60) days prior notice before terminating a contract. Provisions like this are in each of the participating provider contracts we must sign, and this provision cannot be varied because of the State law.
We also understand that the HMO rules in Chapter 191 require a minimum surplus available to pay claims of not less than thirty (30) days of medical payments. This lack of symmetry makes no sense to us and we ask that these obligations be made symmetrical.
Q: How do you respond to Anthems contention that there ought to be an even playing field affecting all insurers, and that special requirements ought not to be imposed upon it?
A: The dissolution and take-over of the Blue Cross Plan presents a unique set of issues that needs to be dealt with. We respectfully seek regulatory oversight to assure that the major statewide payor, with a 47% marketshare, and 45% in our market, be subject to such a requirement, especially when its governance control is changing from a local board of a charitable institution to a major national for-profit that is ultimately governed by a board in Indiana. We would have no opposition to this same requirement being imposed upon other Maine insurers.
Chapter 344 of the Maine law establishes several particular requirements to be satisfied by any entity taking over and converting Blue Cross. We believe the Superintendent is fully authorized to, and properly should, impose additional specific requirements on Anthem in these circumstances.
We believe that the added regulatory oversight proposed by our Standards and Requirements will avert future financing crises in the Maine healthcare system.
Q: Does this conclude your testimony?
A: Yes. I welcome the opportunity to respond to questions the Superintendent and other parties may have on the points I have made.
DATED: March 28 2000
Sandra L. Parker, Esq. Esq. John P. Doyle, Jr., Esq.
Attorney for MHA, Inc. Attorney for MHA, Inc
MHA, Inc. PRETI, FLAHERTY, BELIVEAU,
150 Capitol Street PACHIOS & HALEY, LLC
Augusta, Maine 04330 One City Center
e-mail: email@example.com P.O. Box 9546
JPD\G:\MHA\2000\ANTHEM\TestimonyKempton0328.doc (March 28, 2000 8:19 AM)
Kempton Exhibit 1
*companies whose premium represents 1% of all health premiums
JPD\G:\MHA\2000\ANTHEM\KemptonExhibit1Table.doc (March 28, 2000 8:50 AM)
CERTIFICATE OF SERVICE
The undersigned hereby certifies that on March 28, 2000 a copy of PREFILED TESTIMONY OF DANA KEMPTON, was served via hand delivery, overnight mail or electronic mail on each of the persons listed below.
Jeffrey M. White, Esq.
Catherine R. Connors, Esq.
Portland, Maine 04101
(Anthem Insurance Companies, Inc)
Robert S. Frank, Esq.
HARVEY & FRANK
Two City Center, Fourth Floor
P.O. Box 126
Portland, Maine 04101
(Blue Cross/Blue Shield of Maine)
Judith Chamberlain, Esq.
State of Maine
Department of the Attorney General
286 Water Street
Augusta, Maine 04333-0006
(Bureau of Insurance)
William H. Laubenstein, Esq.
State of Maine
Department of the Attorney General
286 Water Street
Augusta, Maine 04333-0006
(Office of the Attorney General)
Joseph P. Ditre, Esq.
Consumer Health Law Program
One Weston Court, Level One
P.O. Box 2490
Augusta, Maine 04338-2490
(Consumers for Affordable Health Care Foundation/Coalition)
Michele M. Garvin, Esq.
Ropes & Gray
One International Place
Boston, Massachusetts 02110-2624
(Central Maine Healthcare Corporation; Central Maine Partners Health Plan)
Robert I. Goldman
Maine Council of Senior Citizens
27 Bowery Beach Road
Cape Elizabeth, Maine 04107
(Maine Council of Senior Citizens)
Executive Director of the Maine Ambulatory Care Coalition
P.O. Box 390
Manchester, Maine 04351
(Sacopee Valley Health Center, Regional Medical Center at Lubec, Eastport Health Care, Inc., and the Maine Ambulatory Care Coalition)
Maine Peoples Alliance
192 State Street
Portland, Maine 04101
(Maine Peoples Alliance)
Gordon H. Smith, Esq.
Maine Medical Association
30 Association Drive
P.O. Box 190
Manchester, Maine 04351
(Thomas D. Hayward, M.D.,
Maroulla S. Gleaton, M.D.,
And the Maine Medical Association)
Michel Lafond, Esq.
Sulloway & Hollis
P.O. Box 1256
Concord, New Hampshire 03302-1256
(co-counsel for Maine Medical Association)
Donald E. Quigley, Esq.
465 Congress Street, Suite 600
Portland, Maine 04101-3537
(Maine Medical Center)
Sandra L. Parker, Esq.
Attorney for MHA, Inc.
150 Capitol Street
Augusta, Maine 04330
Kellie P. Miller, M.S.
Maine Osteopathic Association
693 Western Avenue
Manchester, Maine 04351
(Maine Osteopathic Association)
DATED: March 28, 2000
John P. Doyle, Jr., Esq.
Attorney for MHA, Inc.
PRETI, FLAHERTY, BELIVEAU, PACHIOS & HALEY, LLC
One City Center
P.O. Box 9546
Portland, Maine 04112-9546
JPD\G:\MHA\2000\ANTHEM\TestimonyKempton0328.doc (March 28, 2000 8:19 AM)
Last Updated: January 21, 2014
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