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Maine.gov > PFR Home > Insurance Regulation> Administrative & Enforcement Actions > Document 733 : INS 99-14 : Hearing Decision
STATE OF MAINE
The Maine Medical Association and the Maine Osteopathic Association, Intervenors and associations of physicians practicing in the State of Maine, provide this Closing Statement to urge the Superintendent to disapprove the Conversion Plan submitted by the Applicants because the Plan is neither complete nor "fair and equitable" and has not been validly approved by the Board of Directors of BCBSME, and to urge the Superintendent to disapprove the Conversion Plan.
Blue Cross Blue Shield of Maine ("BCBSME"), a Maine Nonprofit Hospital and Medical Service Organization, has been engaged for several decades in the business of providing indemnity health insurance benefits and arranging for the provision of health care services to subscribers and enrollees. During the past several years, BCBSME sustained substantial operating losses and its capital surplus has been reduced significantly, although BCBSME continues to meet the financial standards of the State of Maine and the Blue Cross Blue Shield Association required for continued operation. Notwithstanding these losses and reductions in capital surplus, BCBSME currently has a Company Level Risk-Based Capital Ratio of 150%. Hearing Transcript ("Tr.") 4/5/00, p.m., p. 18. Anthem has advised that it has an "expectation" that it will maintain the company level risk-based capital ratio for all its subsidiaries, including its Maine subsidiary at between 100 and 125%. Tr. 4/7/00, a.m., p. 42. Mr. Robert L. Hoyer, head of the national actuarial practice for Arthur Andersen and consultant to the Superintendent, has identified the 100-125% risk-based capital level as "absolutely a minimum level clearly less than optimal" and has suggested that Anthem "should change that management philosophy for all subsidiaries." Tr. 4/5.00, p.m., p. 19. Upon and immediately after the closing of the sale of the assets of BCBSME to a subsidiary of Anthem ("Anthem BCBSME"), the aggregate capital of Anthem BCBSME will be less than the current aggregate capital of BCBSME. Tr. 4/5/00, p.m., p. 23. Anthem has refused to make any commitment or binding obligation to make available to Anthem BCBSME capital resources of Anthem beyond the minimum required to qualify for licensing in Maine. Tr. 4/5/00, p.m., p. 125.
Change of Control Agreements have been in place and available to executives and senior management of BCBSME for several years. Tr. 4/3/00, p.m., pp. 34-38. In February 1999, after initial discussions with Salomon Smith Barney ("SSB") and one or more prospective investors or buyers, the Change of Control Agreements for some 11 executives and senior managers of BCBSME were updated and augmented in anticipation of a conversion and sale of assets of BCBSME. Tr. 4/3/00, p.m., pp. 34-38. The Change of Control Agreements have been provided to assure that senior management personnel "were not put in a position of ingratiating themselves to any potential acquirer and would negotiate aggressively" on behalf of the company. Tr. 4/3/00, p.m., p. 35.
These Change of Control Agreements remain in existence and provide enforceable contract rights to payments of substantial cash compensation and other benefits. Pursuant to the provisions of the Asset Purchase Agreement, Anthem or a designated subsidiary shall assume the obligations under those Change of Control Agreements.
These Change of Control Agreements have not been included in the Conversion Plan and made available for public inspection and copying.
These terms and provisions of these Change of Control Arguments have been designated by management of BCBSME and the Superintendent as "Confidential" and "Highly Confidential" documents. Accordingly, further discussion of terms and provisions of these Change of Control Arguments is set forth in the Confidential Attachment to this Closing Statement. Such discussion will be limited, necessarily, because the Intervenors in this proceeding, including the Maine Medical Association and the Maine Osteopathic Association were not granted access to any documents or hearing sessions deemed to be "Highly Confidential."
With the assistance of SSB, BCBSME negotiated and entered into an Asset Purchase Agreement, dated July 13, 1999, with Anthem Insurance Companies, Inc. ("Anthem"), an Indiana mutual insurance company (the "Asset Purchase Agreement"). The Asset Purchase Agreement provides for the payment of a purchase price of $120,000,000 and provides that such purchase price is subject to downward adjustment. The Asset Purchase Agreement provides that the reductions in the purchase price are to be made to adjust the purchase price for any losses sustained prior to closing and to defray transaction costs and other costs.
In addition, BCBSME engaged Houlihan Lokey Howard & Zukin Financial Advisors, Inc. ("Houlihan Lokey") to prepare an independent appraisal of the fair value of the equity of BCBSME. According to the appraisal report of Houlihan Lokey, dated September 15, 1999, the fair value of BCBSME, as of July 13, 1999, is $102,500,000. Houlihan Lokey was not engaged by BCBSME to update its appraisal report or to adjust or "bring down" its appraisal of the fair value of the equity of BCBSME as of the "Conversion Date" and no such updating Houlihan Lokey appraisal is included in the Conversion Plan. The "Conversion Date" is the date of
completion or closing of the Conversion Plan that has been submitted by BCBSME and Anthem to the Superintendent of Insurance and the Attorney General.
At the time of completion of the negotiation of the Asset Purchase Agreement, the Board of Directors of BCBSME was briefed on the terms and provisions and undertook a review of the proposed Asset Purchase Agreement. According to Mr. William Ryan, the Chairman of the Board of BCBSME, "consultants and lawyers" advised that adequate provisions had been made for the necessary and appropriate capitalization of the Anthem company that is to acquire the assets and continue the business of BCBSME ("Anthem BCBSME"). He suggested that since Anthem BCBSME will be a subsidiary of Anthem and will have "access" to the substantial capital resources of Anthem. Mr. Ryan testified that such "access" to the capital resources of Anthem is equivalent to an agreement that obligates Anthem to provide capital to the subsidiary. Tr. 4/3/00, a.m., p. 75.
In this proceeding, management of Anthem has refused to make any binding commitments to contribute any capital to Anthem BCBSME in excess of the minimum amount required to secure a Certificate of Authority to permit the operation of Anthem BCBSME in the State of Maine. Mr. Hoyer has testified that there is a substantive and fundamental difference between a subsidiary corporations "access" to the capital of a parent corporation and a commitment or agreement to obligate and require a parent corporation to make capital contributions to a subsidiary corporation. Tr. 4/5/00, p.m., pp. 20 and 21.
On September 15, 1999, the Board of Directors of BCBSME voted to authorize and direct the officers of BCBSME to prepare and submit a Conversion Plan to the Maine Superintendent of Insurance and the Maine Attorney General. Applicants Ex. C-23 (Confidential). The requirements for the Conversion Plan are identified in Maine statute, Title 24, §2301-9-D) (the "Conversion Statute") and the Conversion Plan is to provide a "complete description" of the proposed conversion of the nonprofit hospital and medical service corporation to a stock company. The statute requires that the Conversion Plan is to be submitted to the Superintendent of Insurance for review and for determination by the Superintendent whether the "terms and conditions" of the Conversion Plan are fair and equitable," 24 M.R.S.A. 24 §2301-9-D-E(1), and do not "adversely affect the distribution of the [BCBSME]...value" (24 M.R.S.A. §2301-9-D-E(8)) to the charitable trust that is to be established to receive and hold that value for public benefit.
A Conversion Plan was prepared by BCBSME and Anthem, and the Houlihan Lokey appraisal report, dated July 13, 1999, was included in such Conversion Plan. That Conversion
Plan was submitted to the Superintendent of Insurance on September 15, 1999, and the review of the Conversion Plan by the Superintendent of Insurance was begun on that date.
Pursuant to orders entered by the Superintendent of Insurance, the Maine Medical Association and the Maine Osteopathic Association were granted the right to participate as Intervenors in the proceedings to review the Conversion Plan. In permitting the Maine Medical Association and the Maine Osteopathic Association to intervene in this proceeding, the Superintendent of Insurance recognized the central and essential role of physicians in the delivery of health care services to health insurance policyholders and enrollees of health maintenance organizations. See Superintendents Orders dated 11/12/99 and 12/22/99.
During the course of this proceeding, the Maine Medical Association made several discovery requests and filed a Motion to Compel production of information and documents related to Anthems health care delivery policies and practices. Anthem refused to produce the requested information and documents and opposed the Motion to Compel, asserting that such policies and practices of Anthem are irrelevant to this proceeding. The Superintendent denied the Motion to Compel the production of requested materials and ruled that issues related to Anthems provider contracting policies and practices in other states are irrelevant to this proceeding. Order of Deputy Superintendent, 3/22/00. Tr. 4/5/00, p.m., pp. 144-149.
In the second half of 1999, BCBSME incurred unexpected expenses and experienced net losses for the year of approximately $17,600,000. Management of BCBSME attributes the losses to some $10,000,000 of unbudgeted expenses to eliminate prospective Y2K computer problems, to increases in pharmacy benefit costs and to increases in medical claims. In accordance with the terms and provisions of the Asset Purchase Agreement, management of BCBSME calculated the adjustments to be made to the purchase price for the assets of BCBSME and determined that the net purchase price to be paid for the assets of BCBSME is approximately $81,700,000. McGinty Prefiled Testimony, p. 11.
The July 13, 1999 appraisal of Houlihan Lokey has not been updated and adjusted as of the date of completion of the Conversion Plan. The provisions of the Asset Purchase Agreement for the adjustment of the purchase price constitute agreements between the parties to the Asset Purchase Agreement and do not qualify as any adjustment to Houlihan Lokeys independent appraisal of the fair value of BCBSME. An opinion expressed by Mr. Francis McGinty, Chief Financial Officer of BCBSME, that the current fair value of BCBSME is approximately $71,000,000, has been identified as "improper and incorrect," (Tr. 4/5/00, p.m., pp. 13-15), and the consultant to the Superintendent has offered his own opinion is that the current fair value of BCBSME is " somewhat less" than the net purchase price of approximately $81,700,000 that is to be paid by Anthem. Tr. 4/5/00, p.m., p. 17. The consultant to the Superintendent has suggested that sufficient documentation has been provided to enable the Superintendent to make a determination of the appropriateness and adequacy of the Conversion Plan, but on cross-examination, he, the consultant, confirmed that he had not prepared any appraisal of the current fair value of BCBSME. Tr. 4/5/00, p.m., p. 25. During the adjudicatory hearing a request was
made to the Superintendent to make available the work papers of his consultant relating to the consultants opinion concerning the current fair value of the equity of BCBSME and that request was denied. No documentation of any update to the appraisal of Houlihan Lokey is included in the record of this proceeding.
BCBSME has elected to sell its assets to a business subsidiary of Anthem and has elected to satisfy the Maine statutory requirements for such proposed transaction by preparing a "Conversion Plan" and submitting the Conversion Plan for review by the Superintendent of Insurance. The provisions of the Conversion Statute govern the proposed conversion of
BCBSME, a Maine nonprofit hospital and medical and service organization, to a stock insurance company and establish the requirements for the scope, content and review of the Conversion Plan.
In the event that a Conversion Plan is prepared to facilitate and permit the conversion of a nonprofit hospital and medical service organization, the Conversion Plan must be filed with the Superintendent and must be made available in the office of the Superintendent and elsewhere for inspection and copying. The Conversion Plan must satisfy the requirements of the Conversion Statute and must be submitted for review by the Superintendent. The Conversion Statute requires that the Superintendent make provision for review of the Conversion Plan in an adjudicatory hearing. Notice of the adjudicatory hearing must be provided to the public and certain other designated persons, including subscribers, and those persons who are entitled to notice of the hearing must be afforded the right to appear and be heard in the hearing. 24 M.R.S.A. §2301-9-D-C.
A Conversion Plan submitted pursuant to the Conversion Statute, must include "an appraisal of the fair value of the aggregate equity of the converted stock insurer to be outstanding upon completion of the conversion plan...." 24 M.R.S.A. §2301-9-D-I. To the extent that the appraisal report identifies a range of values for the converted stock insurer, the Conversion Plan must include "the methodology for fixing a final value coincident with the completion of the transaction provided for in the conversion plan." 24 M.R.S.A. §2301 9-D-I. The required appraisal:
24 M.R.S.A. §2301 9-D-I(2).
The statute also requires that the appraisal must enable determinations of value for purposes of determining the amount of cash or other assets that subscribers or the charitable trust are entitled to receive under provisions of the Conversion Plan as required by paragraph E of the Conversion Statute. 24 M.R.S.A. §2301 9-D-I(i). The referenced provisions of paragraph E of the Conversion Statute require that shares of capital stock of the stock insurance company (the stock company that exists after the conversion of the nonprofit hospital and medical services organization) shall be transferred to the charitable trust that is to be organized in connection with the conversion of the nonprofit hospital and medical services organization and the Conversion Plan, without any requirement that the charitable trust pay anything for the shares. 24 M.R.S.A. §2301 9-D E (3).
Paragraph E of the Conversion Statute, 24 M.R.S.A. §2301 9-D E, provides that the Superintendent "may not issue final approval of a conversion plan unless the superintendent finds" that:
Finally, the Conversion Statute provides that:
"A director, officer, agent or employee of the organization or any other person may not receive any fee, commission or other valuable consideration whatsoever other than that persons usual and regular salary and compensation for in any manner aiding, promoting or assisting in a conversion under this section or any related transaction, except as set forth in the conversion plan approved by the superintendent".
24 M.R.S.A. §2301 9-D J.
The Superintendent "may not" issue final approval of the Conversion Plan for the reasons set forth below:
Paragraph 9-D-I of the Conversion Statute requires that the Conversion Plan include an appraisal of the fair value of the aggregate equity "of the converted stock insurer to be outstanding at the time of completion of the conversion." 24 M.R.S.A. §2301 9-D-I. In this case, this statutory provision requires that the aggregate equity value of BCBSME, upon and after conversion of BCBSME to a stock insurance company and at the time the assets of that stock insurance company are to be sold, and the fair value of such assets are to be delivered to the charitable trust. This statutory provision also requires that if the appraisal provides that there is a dollar range within which is the fair value of the assets being appraised, a methodology must be included for fixing a final value for the assets at the time of completion of the transaction provided for in the Conversion Plan. Since it is contemplated that the "conversion," the sale of assets and the delivery of proceeds from the sale of assets to the charitable trust, are going to happen simultaneously, a fair and necessary reading of the statute is that the appraisal of the fair value, or the fixing or determination of the "final value," is to be made as of the date of closing of the Conversion Plan transactions.
This interpretation of the statute is confirmed by related provisions of the Conversion Statute found in paragraph 9-D-I (1) that require that the appraisal must "enable" the determination of the amount of cash or other assets that must be delivered to subscribers or to the charitable trust. The cash or other assets are to be delivered at the time of "closing", and a fair reading of the plain language of the statute makes clear that the appraisal must enable the determination of the fair value of assets as of the time of that closing.
The fair value appraisal that is to be made and determined as of the completion of the conversion transactions is to be included as part of the Conversion Plan that is filed with the Superintendent and is to be made available for public inspection and copying is required, as set forth in paragraph I (2) of the Conversion Statute, 24 M.R.S.A. 2301 9-D-I (2). The statute also requires that such fair value appraisal is:
23 M.R.S.A. §2301 9-D-I (2).
While the Conversion Plan does include the appraisal that was prepared by Houlihan Lokey, the Conversion Plan is materially deficient because the Houlihan Lokey appraisal is an appraisal of the fair value of the aggregate equity of BCBSME as of July 13, l999, and is not an appraisal of such fair value of such aggregate equity at the time of the conversion of BCBSME to a stock company and completion of the conversion transactions. The Conversion Plan that has been filed with the Superintendent and made available to the public for review and copying does not include any analyses or other information that would permit a reader to know and understand what is the adjusted fair value appraisal for the equity of BCBSME as of the current date or the completion of the Conversion Plan. There is certainly nothing in the public, non-confidential record of this proceeding that has been identified by anyone that constitutes the complete and detailed description of the elements that constitute the appraisal, the methodology that anyone used in preparing any new appraisal, updating and adjusting the Houlihan Lokey appraisal, and the "sufficient support" for appraisal conclusions that are required by Paragraph I (2) of the Conversion Statute.
The consultant to the Superintendent might be qualified to know and understand what analyses and adjustments must be made to update the Houlihan Lokey appraisal, but he has testified that he has not done that appraisal work. Similarly, while the Superintendent might conclude that he has enough information to make adjustments to the appraisal of Houlihan Lokey, the Conversion Statute does not contemplate and does not permit any such appraisal by the Superintendent. The Superintendents statutory duty is to review an independent appraisal prepared by experts in corporate appraisals on behalf of BCBSME. Moreover, even if the Superintendent is qualified and permitted under the Conversion Statute to undertake the appraisal function himself, he has not identified to anyone, other than perhaps his consultants, the information that he deems material to the appraisal, the methodology that he uses in making the appraisal and the support for his appraisal conclusions. And finally, no such information, methodology or support has been included in the Conversion Plan and made available for public inspection and copying to facilitate and permit review and argument by intervenors in the required adjudicatory proceeding.
In addition, there is no valid excuse for failure to include the required, updated appraisal in the Conversion Plan. It is common practice in corporate transactions to update or "bring down" financial statements and other basic company information through current unaudited financial statements and comfort letters, officer certificates, and purchase price escrow arrangements and related verification or earn-out agreements.
Experienced senior management and transactions consultants should recognize that in this instance the Asset Purchase Agreement could have been prepared to accommodate appropriate and necessary adjustments to the fair value appraisal and the purchase price; that Houlihan Lokey readily could have been engaged to undertake the analysis to update its appraisal; that the Conversion Plan could be updated and augmented by the inclusion of the updated appraisal required by the Conversion Statute; and that the adjudicatory hearing could be continued to permit reasonable and necessary review of the updated appraisal.
None of these possible, available, traditional and commonly used corporate transaction tools have been utilized in this case. The result is that the Conversion Plan is substantially and materially deficient.
The Conversion Statute prohibits the Superintendent from approving the Conversion Plan under these circumstances.
The Superintendent cannot make any finding that the terms of the Conversion Plan are "fair and equitable" because no information concerning Anthem health care delivery policies and practices is included in the Conversion Plan and the Superintendent has determined that all matters concerning Anthem policies and track record related to provider contracting are irrelevant to this proceeding. This action of the Superintendent, after repeated requests and objections made on behalf of Anthem, has precluded adequate and necessary consideration of the question whether the Conversion Plan "would adversely affect, in any manner, the services to be rendered to subscribers." In addition, 24 M.R.S.A. 222 requires that the Superintendent make the same determination before approving the acquisition of the assets of BCBSME.
Paragraph 9-D E of the Conversion Statute requires that the Superintendent make the finding, as a prerequisite to any final approval of the Conversion Plan, that the terms and provisions of the Conversion Plan are "fair and equitable." Paragraph 9-D L of the Conversion Statute, in turn, requires that in making any such determination that the Conversion Plan is "fair and equitable", the Superintendent must consider whether the Conversion Plan would adversely affect, in any manner, the services to be rendered to subscribers. Paragraph 9-D C of the Conversion Statute provides that the Superintendent can approve a Conversion Plan only after
conducting an adjudicatory hearing on the proposed hearing and only after providing notice of the hearing and permitting subscribers, and other persons with rights to appear, to be heard at the hearing.
The services to be rendered to subscribers of BCBSME and other nonprofit hospital and medical services organizations are the health care services that are to be provided by and through physicians and other health care professionals, hospitals and other providers. Paragraph 9-D E (1) of the Conversion Statute makes clear that any adverse affect on the delivery of health care services would have to be viewed as a material factor in determining whether the Conversion Plan is "fair and equitable." Since the statute also requires that the Superintendent must give notice to and permit subscribers to participate in the required adjudicatory hearing, there is virtually no room to conclude that the Superintendent can make a finding, that the implementation of the Conversion Plan will not adversely affect the delivery of health care services to subscribers, without a full and complete review of the issues in the adjudicatory hearing. The Superintendents prehearing orders denying access to information and documents concerning Anthems health care delivery policies and practices, renewed in the course of the adjudicatory hearing, have precluded any meaningful review of the issues related to the delivery of health care services.
In determining that the policies and track record of Anthems contracting with health care providers are irrelevant to this review proceeding, the Superintendent has simply noted that Anthem has agreed to assume the provider contract obligations of BCBSME. The Superintendent has refused to recognize that the provisions of those provider contracts permit unilateral amendment to those agreements upon 30 days notice by Anthem to the contracting provider and permit the institution and implementation of Anthem policies and practices, which may be substantially different from those implemented by BCBSME. The Superintendent has merely asserted that there can be no adverse affect since BCBSME also could institute changes to its policies and practices. Subscribers and other Intervenors in the proceedings have objected to this determination, and there is no valid and appropriate basis for that determination.
Under the standards and review process established by the Conversion Statute, the BCBSME health care delivery policies and practices to date, whatever they are, should be recognized as the base line from which one is to determine whether there will be any adverse change as the result of the conversion transactions under review. That base line does exist and is
what it is, and the Superintendent cannot avoid the public review required by the Conversion Statute simply by concluding that BCBSME could have made, or might make, modifications to its policies and practices.
Because discovery of information and documents concerning Anthem health care delivery policies and practices has been denied, because the Superintendent has deemed the issues of Anthem health care delivery policies and practices irrelevant to this proceeding and because the Superintendent has prohibited review of the issues in the adjudicatory hearing, there is no information in the record concerning such policies and practices. Without any record to provide support, the Superintendent cannot make any finding that the implementation of the Conversion Plan, and the attendant transfer to Anthem of substantial authority and control of the delivery of health care services would not "adversely affect, in any manner, the services to be rendered" to the existing 440,000 subscribers of BCBSME.
The regulation of companies that provide health insurance and health maintenance organizations is instituted primarily to protect the subscribers who are to be the recipients of health care services, and the conversion transactions under review in this proceeding will transfer authority and control of the delivery of health care services to a huge number of Maine residents. The Superintendent cannot approve the BCBSME Conversion Plan under these circumstances.
The Conversion Plan submitted by the Applicants is incomplete, fundamentally flawed and does not satisfy the requirements of the Conversion Statutes and, accordingly, the Superintendent should not approve and should reject the Conversion Plan. The Conversion Plan and the Asset Purchase Agreement have not been validly approved by the Board of Directors of BCBSME and, accordingly, are not enforceable. No action should be taken by the Directors of BCBSME to ratify their votes to approve the Conversion Plan and the Asset Purchase Agreement without substantial augmentation and modification of such plan and agreement, respectively, and without fresh and comprehensive analysis of the augmented and modified plan and agreement under the current circumstances of BCBSME.
The Change of Control Agreements granted by BCBSME should be included in the Conversion Plan made available for public inspection and copying as required by the Conversion Statute.
These proceedings, including the adjudicatory proceedings, should be continued and remain open to review any revised Conversion Plan and Asset Purchase Agreement, and the Change of Control Agreements, and to permit full review and hearing of the question whether the implementation of the Conversion Plan will adversely affect in any manner the delivery of health care services to subscribers.
MAINE MEDICAL ASSOCIATION MAINE OSTEOPATHIC ASSOCIATION
Michel A. LaFond Kellie Miller, Executive Director
Sulloway & Hollis, P.L.L.C. 693 Western Avenue
Attorney for Maine Medical Association Manchester, Maine 04351
9 Capitol Street, Box 1256 email@example.com
Concord, New Hampshire 03302-1256
603-226-2405 - fax
Gordon H. Smith
Maine Medical Association
30 Association Drive
P. O. Box 190
Manchester, Maine 04351
CERTIFICATE OF SERVICE
The undersigned hereby certifies that on April 14, 2000 a copy of the Closing Statement of the Maine Medical Association and the Maine Osteopathic Association was served via United States mail, first class postage prepaid, on each of the persons listed below.
Robert S. Frank, Esq. Michele M. Garvin, Esquire
Harvey & Frank Ropes & Gray
Two City center One International Place
P.O. Box 126 Boston, Massachusetts 02110-2624
Portland, Maine 04112 e-mail: Mgarvin@Ropesgray.com
fax - 207-775-5639 (Central Maine Healthcare Corporation;
e_mail: firstname.lastname@example.org Central Maine Partners Health Plan)
(Blue Cross/Blue Shield of Maine)
Judith Chamberlain, Esq. Bonnie Pose, Executive Director
State of Maine Maine Ambulatory Care Coalition
Department of the Attorney General P. O. Box 390
6 State House Station Manchester, Maine 04351
Augusta, Maine 04333_0006 e-mail: email@example.com
e_mail: firstname.lastname@example.org (Sacopee Valley Health center, Regional
(Bureau of Insurance) Medical center at Lubec, Eastport Health
Care, Inc. and the Maine Ambulatory
William H. Laubenstein, Esq. Care Coalition)
State of Maine
Department of the Attorney General Joseph P. Ditre, Esq.
Consumer Health Law Program Consumer Health Law Program
One Weston Court, Level One
One Weston Court, Level One P. O. Box 2490
P.O. Box 2490 Augusta, Maine 04338-2490
6 State House Station e_mail: email@example.com
Augusta, Maine 04333-0006 (Consumers for Affordable Health Care
e-mail: firstname.lastname@example.org Foundation/Coalition)mailto:email@example.com
(Office of the Attorney General)
mailto:firstname.lastname@example.orgMaine Peoples Alliance
192 State Street
Portland, Maine 04101
(Maine Peoples Alliance)
Donald E. Quigley, Esquire
465 Congress Street, Suite 600 mailto:Mgarvin@Ropesgray.commailto:Rgoldma1@maine.rr.commailto:email@example.com:MPA@gwi.netmailto:firstname.lastname@example.org
Portland Maine 04101_3537
(Maine Medical center)
Sandra L. Parker, Esq.
Attorney for MHA, Inc.
150 Capitol Street
Augusta, Maine 04330
James B. Zimpritch, Esquire
Jeffrey M. White, Esquire
Catherine R. Connors, Esquire
Pierce Atwood mailto:email@example.com
One Monument Squaremailto:firstname.lastname@example.org:email@example.comPortland, Maine 04101
(Anthem Insurance Companies, Inc.)
Michel A. LaFond, #8932
Sulloway & Hollis, P.L.L.C.
9 Capitol Street, Box 1256
Concord, New Hampshire 03302-1256
Attorneys for Maine Medical Association
Last Updated: January 22, 2014
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