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Maine.gov > PFR Home > Insurance Regulation > Hearing Decision Index > Document 620 : INS 99-14 : Hearing Decision
STATE OF MAINE
NOW COMES Intervenor, MHA, Inc. (MHA), through its undersigned counsel, and submits this Prefiled Testimony of David A. Peterson, President of The Aroostook Medical Center, consistent with the terms of the Superintendents Procedural Order of November 4, 2000.
Q: Please identify yourself and your place of employment.
A: David A. Peterson, President and Chief Executive Officer for The Aroostook Medical Center, Academy Street, Presque Isle, Maine 04769.
Q: How long have you been employed in this capacity, and prior to holding this position, what position did you hold?
A: I have served as President and CEO of The Aroostook Medical Center since 1987. Prior to this, I served from 1976 onward as Chief Financial Officer for The Aroostook Medical Center.
Q: Please provide a brief summary of your educational background and related matters.
A: I am a native of Stockholm, Maine. I received a B.A. in Political Science and a Masters of Business Administration, both from the University of Maine in Orono. I worked at Arthur Young and Company, CPAs from 1973 to 1976 and have been employed at The Aroostook Medical Center from 1976 onward.
Q: Do you have an opening statement?
A: I do. My testimony will relate to general and specific concerns that I have, and which I believe are widely shared within the Maine healthcare management community, relative to the proposed acquisition of Blue Cross Blue Shield of Maine by Anthem. In general, I am concerned that the entire character of a major component of the healthcare insurance system in this state may be changed in a largely negative fashion, particularly as it will affect small and rural healthcare providers and their service populations, if certain safeguards are not included in the final acquisition agreement. Specifically, I am concerned that a certain body of past practices and formal programs which have characterized the relationships between BCBS of Maine and the States providers may disappear or may be dramatically altered, to the significant detriment to those providers and those they serve.
Q: How significant is Blue Cross Blue Shield of Maine (BCBSME ) to your Hospital?
A: It is very significant. It represents approximately 15.3% of the revenue received by the Hospital, and among non-governmental payors, it represents a 29.6 % share. The total revenue received by the Hospital from Blue Cross over each of the past two or three years has been:
1999 1998 1997
$5,418,203 $5,918,078 $6,398,960
Our current fiscal year budget for our fiscal year ending September 30, 2000, anticipates $5,869,562 in revenue from BCBSME.
Q: Could you comment on the significance of BCBSME to the physicians who practice at your hospital?
A: Certainly. Let me break this into a couple of pieces. Our Hospital has a physician affiliate, Horizons Health. It is a tax-exempt non-profit sister corporation of the Hospital, and shares the same parent, TAMC, Inc. It employs 18 physicians and 13 Physicians Assistants. Of these, 11 are primary care physicians (PCPs) and the others are specialists in the area of obstetrics/gynecology, pulmonology, psychiatry and general surgery.. For this physician group, Blue Shield revenues have amounted to 15% in the most recently completed year, and 14% in the year before that. The actual revenue figures are as follows:
FY1999 FY1998 FY1997
$802,188 $538,367 $293,018
For the current fiscal year, this physician group has budgeted projected Blue Cross and Blue Shield revenues of $ 1,039,798. While I do not have access to comparable figures for other physicians or physician groups on our communitys medical staff, I believe their revenue percentages to be similar as they are treating the same general population. The revenue totals for our group likely represent less than a third of the total for all physicians in our active medical staff. Therefore annual physician revenues for physicians in our overall service area probably are around $3.0 million.
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 Health Policy and Legislative Council and was actively involved in developing these Standards.
A: A dominant factor in our thinking has been the financial difficulties facing Tufts Health Plan and Harvard Pilgrim Health Care, among others. We were deeply concerned with the financial exposure to our Hospital and Medical Staff from these developments.
Q: Could you comment on the exposure faced by The Aroostook Medical Center from the Tufts insolvency/liquidation and the Harvard Pilgrim receivership proceedings?
A: Currently, we have $ 441,950 in past due payments owed by Tufts and Harvard to the Hospital. We have an additional $ 35,017 due to Horizons Health from these entities. Approximately ninety percent of these amounts is attributable to Tufts.
Q: What are the prospects of recovery?
A: The proceedings before the New Hampshire Commissioner of Insurance have authorized ongoing payment to providers only for bills for services rendered on and after December 20, 1999. We are totally exposed for payments prior to that date. According to information provided on the BOI website, payment for services rendered prior to December 20, 1999 will be subject to the outcome of the liquidation proceedings, and we may receive a "pro-rata" payment of some type. 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 greatly troubled by having to rely upon the New Hampshire Department of Insurance as the governmental entity responsible for 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 and other provider associations posted. I would have had more confidence, however, if our Maine BOI had been directly involved in the running of these proceedings.
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 at the time Tufts Health Plan obtained a license to do HMO business in Maine, it obtained approval from the Maine Superintendent to do so through a New Hampshire domiciled corporation, and not a Maine domiciled corporation. As a result, insolvency proceedings have been regulated by the New Hampshire Commissioner, with the Maine Superintendent left primarily in a monitoring role. The MHA and I want to avoid any repeat of this scenario and want to assure that the Maine BOI will always be in the drivers seat for purposes of directly regulating all Anthem activities in Maine.
Q: Is this the basis for 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. Similar to the other witnesses in behalf of MHA, we have much more confidence in the ability of the Maine BOI to address and respond to the needs of Maine providers than an out-of-state regulatory entity.
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 constitutes over 15% of our Hospital revenues and another 15% of our group practice revenues. I understand that statewide, Blue Cross currently claims on its website that it serves over 40% of the Maine population. A recent report of the Consumer Division of the Bureau of Insurance reports a market share for 1998, among non-governmental payors, for Blue Cross of 47% statewide. This percentage share is set forth in a table appearing at Appendix B of that report. For our Hospital, as I testified earlier, Blue Cross accounts for a 29.6% share of non-governmental payors. Given these numbers, 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. The second Standard and Requirement seeks 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 do you support this proposed requirement?
A: Again, the uncertainties facing Maines hospitals and providers that have arisen in the Tufts context have motivated us to seek additional protective requirements in order to prevent these problems from occurring in the future. Further, our concerns are especially heightened in the context of a payor that has 47% of the non-governmental health insurance market statewide, and 15% of our business, and almost 30% of our non-governmental business.
Q: Do you have another basis for seeking this requirement?
A: Yes We seek to make meaningful and enforceable a commitment that Anthem itself stated in its February 1, 2000 BOI filing, in response to Question 7(D), page 15, as follows:
7D. Any other arrangements to ensure that benefits are continued as specified in this section.
As stated above in the response to Section 4203(3)(R), at the Closing Anthem will cause Anthem BCBS to have capitalization equal to at least 100% of the NAIC Risk Based Capital standards for Managed Care Organizations. In addition, the provider contracts of BCBSME to be assumed by Anthem BCBS contain "hold harmless" provisions to protect enrollees and covered persons. Finally, in connection with the maintenance of the right to use the Blue Cross and Blue Shield name and mark, Anthem will certify to the Blue Cross and Blue Shield Association that it guarantees to the full extent of its assets all of the contractual and financial obligations of Anthem BCBS to its customers.
We understand the reference to "Anthem" in this context means the Anthem parent of Anthem BCBS, the local entity through which the Maine Blue Cross business will be carried out. Among the "contractual and financial obligations" to the Maine customers are to assure that Maine providers are paid.
If Anthems own application stresses the importance of this guarantee to "ensure" that benefits are to be continued, then the Superintendent ought to make this commitment meaningful and enforceable by making a parental guarantee an express, enforceable condition of his approval order.
Q: Can you provide further background as to the reasons behind this request?
A: Like other MHA witnesses, I feel that if the Anthem parent is already committed, as part of its overall Blue Cross agreement to guarantee the obligations of the local entity, to the full extent of the Anthem parents assets, then the imposition of this requirement is part of the Maine approval process will serve to assure this commitment is meaningful and it is one that the Maine Superintendent can enforce. We believe it will go a long way toward assuring the ongoing financial integrity of the Maine operation and will prevent a recurrence of the Tufts and Harvard problems in the future.
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 hospital-based specialty physician group that is the sole "franchised 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 these specialists 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 heightened concerns on this issue in the context of the Blue Cross plan?
A: Certainly. In the case of a payor with a 15% share of our market and almost 30% of our non-governmental 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 Deputy Superintendent issues a ruling on March 22 that deemed this "separate contracting" issue to be "irrelevant" to this proceeding?
A: Yes. I cannot understand the basis for such a decision and hope the Superintendent will reconsider and reverse the ruling based on the factors I and other MHA witnesses have noted.
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 .
Q: Why has this been important to your Hospital?
A: It has assured us a significant revenue stream without peaks and valleys , particularly in an environment where the business practices of some other payors has leaned heavily in the direction of delaying or minimizing cash flow to providers. Because our employees and suppliers need and expect regular and timely payments , this predictable cash flow feature of our historical contractual relationship with BCBS of Maine has been a critical factor in the financial survival of small, routinely cash-strapped Maine hospitals.
Q: What is the second Blue Cross payment 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, providers have had a relatively positive experience with Blue Cross and Blue Shields prompt payment and accurate processing of claims.
Q: How is Blue Cross definition of "clean claims" different from other payors?
A: Other payors have from time to time given us a very difficult time in processing claims, in what appears to us to be an obvious attempt to create cash flow delays, thereby financially advantaging the payors. While most agree to promptly pay "clean claims", the interpretation of "prompt" and "clean" is often problematic in practice. For example, we commonly are told by other payors, in response to inquiry about over due payments that a claim was not received and must be resubmitted. This seems to happen more frequently when the payment amount is larger than usual. Other common explanations are that "the patient is not in our plan", when in fact he/she is and this is easily established after the claim has been in a "follow up" pile until the hospital makes inquiry. Lack of a necessary referral record, which turns out to be elsewhere in the insurers system is another common cause for delaying payment of clean claims. Again, we have largely been spared these negative experience in the context of our Blue Cross claims, for which we are grateful. We seek to assure that Anthem continues the timely payment practices Blue Cross has carried out for clean claims.
Q: What impact does this have on you?
A: These delays, planned or not , create significant cash flow problems for which there are no incentives to cause the payor to minimize. In fact, the financial incentives to the payor are exactly opposite to stretch out payment as long as possible. These types of problems fortunately have been relatively minor in the case of the major not-for-profit insurer in Maine, BCBS of Maine.
Q: What is the third prong of Blue Cross 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, more extensive than that of other payors. My colleagues and I on the MHA HPC are concerned that Anthem management, located 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 are also concerned about the potential for "selective contracting" where Anthem might choose to contract with some hospitals and physicians, but not others in an effort to extract greater price concessions or lower administrative costs.
Q: Could you provide a bit more detail on the extent of the network Blue Cross Blue Shield of Maine maintains in the service area served by your Hospital?
A: I am attaching as Peterson Exhibit No. 1, a printout we obtained from the BCBSME website, that displays each of the primary care physicians or groups of physicians in the Blue Cross network that serve Aroostook County. This printout of primary care physicians numbers 18 pages and sets forth approximately 70 groups or individual physicians in primary care (including family practice and pediatrics), which serve Aroostook County.
I am also attaching as Peterson Exhibit No. 2, a printout of the specialty groups or individual physicians serving Aroostook County, again obtained from the BCBSME website. This numbers 40 pages and sets forth over 150 specialists or groups of specialists. This is a very extensive network, and to my knowledge more extensive than that of any other health insurer in the State.
Q: What makes you think that Anthem may not maintain the previously existing Blue Cross network?
A: We have more confidence in a Maine-based and Maine-governed non-profit entity than we do in a subsidiary of an Indiana for-profit parent. We are more concerned when we review some of the Anthem filings, one of which indicates that Anthem may explore "selective contracting". I am informed that Anthems initial application to the Bureau, September 15, 1999 Form A filings, pp. 22-23 states as follows:
Provider contracting. Anthem/BCBSMEs contracting philosophy will be to maintain the most cost-effective provider networks in the local marketplace through a combination of enhanced fixed-price contracts with Hospitals an ancillary providers, broad risk-sharing with physician groups, and continuous assessment and retooling of other arrangements. Although Anthem/BCBSME expects to maintain contracts with most physicians and professionals as well as Maines hospitals, there may be opportunities for selective contracting in specific target areas.
We fear that Aroostook County, for a variety of reasons, will be the geographic venue for Anthems pursuit of "opportunities for selective contracting and that my Hospital or some of the physicians practicing at my hospital may be "selected out" as being less rewarding economically, or having higher administrative costs.. Aroostook County covers the largest geographic area of any county east of the Mississippi. It is more sparsely populated than many other counties in Maine. Historically, we have had difficulty attracting certain types of physicians and specialists. These are some of the reasons we fear Aroostook County could be adversely affected by any strategy involving "selective contracting".
Q: What advice do you have for the Superintendent of Insurance on this score?
A: I understand he has wide latitude under Chapter 344 and the statutory provisions this enacted. He is required to consider a variety of public interests and impacts on subscribers and other affected publics
We view it to be entirely within the scope of his mandate to impose as a requirement that Anthem maintain the existing network historically established by BCBSME well into the future. We believe an approval requirement mandating that Anthem take all reasonable steps to maintain this network for at least five years following its acquisition of Blue Cross is appropriate.
Q: How do you respond to Anthems contention that this would be a condition not imposed on other health insurers and would, in that sense, constitute an uneven playing field?
A: I understand that BOI figures in the Consumer Divisions Report, based upon 1998 health insurance premiums, show that for that year, the current Blue Cross operation had a 47% market share in Maine. As I have testified above, the Blue Cross share of our market is very significant at 15% of our total revenues and almost 30% of our non-governmental revenues. Given these numbers, I believe there is a heightened public interest in assuring this very large insurer continue to meet the public responsibilities historically undertaken and maintained by BCBSME.
Q: If Anthem were under this kind of regulatory requirement, wouldnt it be possible for you and other providers to negotiate for higher prices, with Anthem being required to agree to these higher prices as a condition of maintaining its approval status?
A: For a number of reasons, we would continue to bargain fairly with such an entity. It has 15% of our market and a 30% share of payors other than Medicare and Medicaid. Blue Cross, therefore insures a very substantial portion of the population we serve. Further, we would not be opposed to language in the approval requirement that referenced an obligation on Anthems part to "exercise reasonable commercial efforts" or qualifies to that effect. Here, we note that the New Hampshire condition includes language requiring Anthem to "exercise all commercially reasonable efforts to maintain the existing Blue Cross Network for thirty-six months." Such a condition in Maine would assure regulatory oversight by the Superintendent and in our view, would help assure that the Anthem takeover was not prejudicial to the interests of Maine subscribers and enrollees, and the providers who serve them. Again, we ask for a five year imposition of such a requirement in Maine because we believe it to be more important in our significantly larger, more rural state.
Q: Could you describe the potential impact on your Hospital if these historic Blue Cross network maintenance practices are not continued?
A: A n intensely competitive market situation would likely emerge wherein hospital and other providers would be faced with the potentially crippling loss of a major market share to other providers unless the hospital contracts on terms it cannot live with in the long run. Or, in the worst case, the hospital is push to closure by this major payors outright refusal to contract, and the population is left with greatly diminished choices which have been dictated by an entity with no connection with or understanding of the area impacted. In our case, loss of 15% of our business would significantly limit our ability to maintain and improve services and would ultimately threaten the quality of the care we could continue to deliver.
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 such a significant share of the market. Our Hospital and our medical group have a responsibility to serve the employers and patients within our community, many of whom have historically chosen Blue Cross coverage. 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.
Q: Are you aware that the Deputy Superintendent issues a ruling on March 22 that deemed this "statewide network" issue to be "irrelevant" to this proceeding?
A: Yes. I was distressed to learn this and hope the Superintendent will reconsider and reverse the ruling based on the factors I and other MHA witnesses have noted. This "statewide network" issue is especially important to Aroostook County whose citizens may well be deprived of quality health care if the major commercial payor is given free reign to "select out" our Hospital, physicians and other 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 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 major market share, we would be reluctant to experiment with other payors and self-insured employers. I am aware further that the Deputy Superintendent has initially deemed this issue to be "irrelevant" and I join other MHA witnesses in urging that the Superintendent reconsider and reverse this ruling.
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 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 the participating provider contracts we sign.
We also understand that chapter 191 of the BOI regulations governing HMOs includes a provision establishing a minimum surplus requirement for HMOs with $50 million or less of annual premium to have an ongoing surplus exceeding thirty (30) days of its medical payments to providers.
Therefore, providers are on the hook to provide services for at least sixty days, while payors are only obligated to maintain surplus reserves sufficient to pay them for 30 days. In the case of Tufts, this lack of symmetry has been unjust and unfair to providers, and will cause us to sustain significant uncompensated losses.
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 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.
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\TestimonyPeterson0328.doc (March 28, 2000 8:42 AM)
CERTIFICATE OF SERVICE
The undersigned hereby certifies that on March 28, 2000 a copy of PREFILED TESTIMONY OF DAVID A. PETERSON 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\TestimonyPeterson0328.doc (March 28, 2000 8:42 AM)
Last Updated: August 22, 2012
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