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> Document 742 : INS 99-14 : Hearing Decision
STATE OF MAINE
IN RE: APPLICATION OF ASSOCIATED HOSPITAL SERVICE OF MAINE, d/b/a BLUE CROSS AND BLUE SHIELD OF MAINE, TO CONVERT TO A STOCK INSURER AND VOLUNTARILY LIQUIDATE AND DISSOLVE
IN RE: APPLICATION OF ANTHEM HEALTH PLAN OF MAINE, INC., TO ACQUIRE THE ASSETS OF ASSOCIATED HOSPITAL SERVICE OF MAINE, d/b/a BLUE CROSS AND BLUE SHIELD OF MAINE, AND RELATED TRANSACTIONS Docket NO. INS 99-14 (CONSOLIDATED)
CLOSING STATEMENT AND BRIEF
NON-CONFIDENTIAL VERSION
The Maine Hospital Association (MHA) and its 38 member community hospitals urge that the Superintendent issue a Final Approval Order which includes: . . . . a set of standards that . . . require[s] Anthem to maintain a high level of positive provider and consumer relations and business practices if [its] plans to purchase Blue Cross and Blue Shield of Maine are approved…. MHA Friday Report of February 25, Applicant’s Exhibit 81, Anthem’s Examination of MHA Witness Behre, Afternoon Session Transcript p. 18 - 19. Proposed Standards and Requirements that MHA Urges be Incorporated Into Final Order of Approval To fulfill the preceding goals of its Board, the MHA respectfully urges the Superintendent to incorporate the following specific standards and requirements into his Final Order of Approval. Each of these is necessary to fulfill one or more of the several statutory provisions of the conversion statute and the Insurance Code, and the specific review criteria laid out in the Superintendent’s Notice of November 4, 1999. Supporting Argument
Anthem Maine will be a Maine domiciled corporation at the outset. Anthem has stated a present intention to seek and obtain the Superintendent’s approval if it decides to change this status at a later date. In light of the recent negative experiences relating to Tufts New England (TNE), discussed in greater detail below, MHA urges that Anthem Maine be explicitly required to remain a Maine domiciled insurer, unless and until approval is sought and obtained from the Superintendent. Further, MHA urges that the intervenor parties and the public be notified and given the right to be heard on any request for such approval. The MHA acknowledges that current provisions of §222 and Chapter 56 require Anthem Maine to obtain BOI approval in the hypothetical event of a domicile change. The Final Order must expressly include this requirement to assure public notice of any future change, and further to assure that this requirement remains permanently applicable to Anthem, regardless of future legislative changes. Accordingly, pursuant to 24 M.R.S.A. § 2301(9-D)(E)(1) and 24-A M.R.S.A. §§ 222 and 4204(7), the Superintendent’s Final Order ought to require:
These standards and requirements are authorized and required by S.C.3, 24-A M.R.S.A. §222(7)(A)(3); S.C.4, 24-A §§222(7)(A)(4), "unfair or prejudicial to policyholders or enrollees…"; S.C. 8, 24-A M.R.S.A. §222(7)(A)(7), "adversely affect the contractual obligations … [or] ability and tendency to render service in the future to its policyholders and the public …"; S.C.10, 24-A M.R.S.A. §2301 (9-D)(E)(1) and (9-D)(L); S.C. 17, 24 M.R.S.A. §2301(9-D)(E)(9); S.C. 22, 24-A M.R.S.A. §3483(2)(d); S.C.24, 24-A §3484(2) adverse effect on BCBSME creditor; and S.C. 26, 24-A M.R.S.A. §§4203 – 4204. II. The Superintendent Must Impose Conditions And Requirements On The Approved Conversion To Protect Patients By Assuring Payments To Hospitals In The Event Of Insolvency. Throughout these proceedings, Anthem has contended that compliance with generally applicable statutory requirements of Title 24-A will be sufficient to protect Maine enrollees and subscribers, and related public interests. The Blue Cross Conversion statute, P.L. 1997, ch. 344, 24 M.R.S.A. §2301(9-D), authorizes and directs the Superintendent to do much more. The Superintendent properly ought to exercise this authority and related authority in the Code, in the case of a payor that has over 440,000 policyholders and enrollees, a 47% share of the medical insurance premium payments, a 20-30% share of nongovernmental payments at many Maine hospitals, and annual projected medical benefit expenses of [Redacted – Confidential]. See MHA-1, Behre Testimony, MHA-1-Behre-5 and MHA-4, Peterson Testimony; MHA-5, Kempton Testimony. Attorney General Exhibit 26. In this rural State, the viability of community hospitals is essential to the welfare of Maine consumers and employers, as well as to the Maine economy as a whole. The interests of consumers and employers who are Anthem subscribers, and the public in general, can be protected only if the Superintendent strengthens the minimum solvency and surplus requirements that apply to Anthem Maine and to Anthem’s conduct in managing and controlling that entity. Anthem Maine’s adherence to minimum statutory provisions will not achieve this result, but rather will create a real risk of a repeat of the Tufts scenario. Once again, the parent of the Maine licensed entity could "just say no" to a call for additional capital needed to fulfill required surplus and capital standards, or could otherwise cut off support to a losing Maine venture. This time, the negative impact on those receiving and those delivering medical benefits would be much more severe.
In the very unfortunate event of an insolvency on the part of Anthem Maine, Maine hospitals have no "deep pockets" to absorb the hit. The serious problems caused for Maine hospitals by the TNE insolvency would pale in comparison to the havoc a Maine Blue Cross insolvency would wreak. Maine hospitals would have nowhere to turn for the financial resources needed to continue to provide services to Maine’s consumers, subscribers and enrollees. As MHA Vice President for Finance, Kevin Behre, explained, the Medicare reimbursement rate in Maine ranks 50th out of the 50 states, and the accuracy of this ranking has been acknowledged by the Administrator of the Federal Health Care Financing Administration in recent conversations with MHA. Tr. (April 6 Afternoon Public Session) at 30-32. As a result of this low Medicare reimbursement rate, Maine hospitals receive only about 80% of the actual cost of providing service to Medicare beneficiaries. In the case of TNE, the generically applicable health insurance and HMO requirements for financial adequacy have not been sufficient to assure that benefit payments are in fact made to providers who continue to provide services to enrollees and subscribers. At the end of calendar year 1999, as Mr. Behre testified, Maine hospitals were owed approximately $20 million by TNE. MHA-1, Behre-2. Claims filed prior to December 20, 1999, may well be unrecoverable. See Exhibit MHA-5 Kempton Testimony, pp. 6-7; Exhibit MHA-3-Diggins-1, p. 5 (adopted by Amberger). Maine law protects individual patients and subscribers from the immediate financial impact of such insolvencies and the resulting non-payment, because statutorily required provisions of Maine provider contracts bar hospitals from billing or collecting payment for these claims from the patients themselves. See 24 M.R.S.A. §4204(6). This "hold harmless" protection, however, cannot erase, and indeed exacerbates, the financial impact of these unpaid claims on hospitals already receiving reimbursement from Medicare and other sources that is inadequate to cover the cost of providing service. Worse still, these hold-harmless provisions can encourage a carrier facing insolvency to conclude that provider claims have low priority and may be back-burnered, or even ignored. The end result is not only a serious cash flow crisis, but a potentially devastating, or even fatal, impact on the ability of hospitals to continue delivering the services on which their communities depend. See Exhibits MHA-1, Behre Testimony, and MHA-5 Kempton Testimony, Tr. (April 6 Afternoon Public Session) at 32-33. Ultimately, these elements combine to adversely affect the ability of subscribers and other Maine citizens to obtain needed services. These potentially severe negative impacts must be eliminated, or significantly ameliorated, through imposition by the Superintendent of standards and requirements necessary to assure fulfillment of each of the 26 Superintendent Criteria, and the underlying statutory provisions.
Anthem’s filings affirmatively commit to maintaining only the minimum statutory surplus required by Maine law. Certificate of Authority Application, Applicants’ Exhibit 3A, February 1, 2000, part I, 3R, p. 11, website version, Part II, § 4204(7), p. 17. Anthem CFO, Mr. Smith provided non-confidential prefiled testimony that "we typically maintain subsidiary capitalization of at least 100-125% of CALRBC". He stated further that "Anthem anticipates infusing over $11 million to initially capitalize [Anthem Maine] at 125% CALRBC". Smith Adopted Prefiled Testimony, p. 7.
[Redacted – Confidential]
This dividend practice makes it likely that any Anthem Maine net operating income above minimum statutory requirements will not stay on Anthem Maine’s balance sheet but rather will be dividended to the super parent whenever regulatory standards permit. Significantly, Anthem has made a firm commitment only to maintain a surplus level for Anthem Maine equal to 100% of the "company action level risk-based capital ("CALRBC"), as defined by 24-A M.R.S.A. §6451(8)(A) and determined in accordance with the risk-based capital statutory standards of Chapter 79, newly effective for HMOs in Maine as of September 18, 1999. 24-A M.R.S.A. §6451-A. In filings and testimony, Anthem witnesses stated that it "intends" and "anticipates", without quite promising, an initial capital infusion resulting in 125% of (or 1.25 x) the CALRBC. This 125% CALRBC factor is required by statute only for an insurer with a "negative trend" to avoid triggering a "CALRBC Event". See Id. §6453(1)(A)(2). Should Anthem Maine rehabilitate BCBSME operations to the extent that there is no risk of "negative trend" classification, Anthem Maine would be free under the statute and its application assurances to reduce its CALRBC from 125% to 100%. [Redacted – Confidential].
Anthem’s proposed Insolvency Plan fails to meet statutory requirements in several key respects. Section 4204(7) states that: The Superintendent shall require that each health maintenance organization have a plan for handling insolvency that allows for continuation of benefits for the duration of the contract period for which premiums have been paid and continuation of benefits to covered persons who are confined on the date of insolvency in an inpatient facility until those covered persons are discharged or upon expiration of benefits. (Emphasis added) Anthem’s insolvency plan as proposed falls short of providing the necessary assurance to Maine citizens. ". This Insolvency Plan must, by statute, address:
As a practical matter, the Plan must also address:
Section 4204(7)(A)-(D) gives the Superintendent broad authority to impose additional standards if he deems the carrier’s proposed plan to be inadequate. These powers include the power to require adequate insolvency insurance, provider contract provisions requiring continuation of services, insolvency reserves covering a notice period for termination of service, and whatever arrangements are needed "to ensure that benefits are continued . . .." Id at §4204(7)(D). Anthem’s February 1, 2000 Certificate of Authority Application, Applicants’ Exhibit 3-A, p. 17 website version, states in response to an application element fulfilling the standards of 4204(7): 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. Unless higher tier Anthem entities are compelled by the Final Order to replenish CALRBC, the first sentence of Anthem’s proposed Insolvency Plan does not afford providers any meaningful protection in the event of an insolvency. Moreover, at the point in time of an Anthem Maine insolvency, its surplus will by definition have been exhausted. Maine hospitals have already discovered in other insolvency proceedings that current premium revenue of the distressed health plan is available only to pay for medical services provided on and after the date that the insolvency proceedings commence. See Exhibits MHA-1-Behre-1, MHA-1-Behre-2, MHA-1-Behre-4, MHA-3 (Diggins Testimony Adopted by Amberger) p. 5. The second sentence of the Insolvency Plan touts the "hold harmless" provisions that are required elements in a Maine provider contract. This provision makes the providers’ predicament far worse, as they are precluded from billing their customers, the patients, in the event of an insolvency. The third sentence of the Insolvency Plan urges that providers and their patients should be reassured by the ability of Anthem Maine to draw on the resources of the Anthem Blue Cross system and Anthem’s commitments under its agreement with the Blue Cross Association of America, the "Blue Master Agreement". The COA filing states that Anthem "guarantees to the full extent of its [Anthem super parent’s] assets all of the contractual and financial obligations of Anthem BCBS to its customers." [Redacted – Confidential]
BCBSME [Redacted – Confidential] witnesses also acknowledged that this Blue Master Agreement created no rights that providers could seek to enforce legally. This distinction that enrollees are customers, but providers are not, is distressing to Maine hospitals for several reasons. First, hospitals do have participating provider agreements with the Blue Cross Plan. Second, the continued existence and availability of hospitals and other provider services is critical to the well-being of BCBS subscribers and enrollees. Any financial peril or forced demise of a community hospital will immediately diminish the quality of, and access to, life-saving medical resources, and will significantly increase the economic cost of such services in terms of travel time, time away from jobs, and related impacts to patients and families. Such a forced demise will further deprive consumers of important and cost saving prevention and public health services. As a consequence of the hold harmless language, the enrollees and their employers would have no out-of-pocket cost that the Anthem super parent would be required to honor under the Blue Master Agreement. Accordingly, the Anthem Blue Cross Master Agreement affords providers, and the patients served by them, no additional security whatsoever against the financial devastation that would result from an insolvency event. In all events, Anthem’s insolvency plan set forth in the filings makes no commitment and provides no enforceable requirement that the super parent’s $1.9 billion surplus will be drawn down upon to fund any future deficiencies in Anthem Maine CALRBC requirements. This poses great risk that an Anthem Maine insolvency would be catastrophic for the direct customers of Anthem Maine and the providers who would continue to treat them. Based on the experience with the Tufts insolvency and the relative size of Anthem Maine, the potential exposure to Maine’s health care providers may exceed [Redacted – Confidential] in 2001 and will grow substantially over future years. The potential financial calamity of unpaid claims of this magnitude is self-evident, and it is essential to protect against it by requiring Anthem to make the substantial resources of its larger system more directly and immediately available, and to limit the use of dividends as a means of diminishing capital to minimal levels at the local tier.
In light of [Redacted – Confidential]
a further measure must be taken in this proceeding, in order to protect Maine providers and their patients. Because Anthem Maine has made no commitment to continue indefinitely the provision of indemnity health plans, it is possible that the statutory controls over "extraordinary dividends" will disappear. If, at some future date, Anthem elected to become solely an HMO or an HMO/POS, the extent to which various provisions governing capital accounts apply to it will be governed by section 4222-B. That section, in turn, incorporates various of the requirements of section 222 but does not include the limitations on the size and frequency of extraordinary dividends. Id. § 4222-B (5). Accordingly, in establishing reasonable requirements pursuant to § 4204 (7), the Superintendent must also specify that, as a condition of his approval, the extraordinary dividend limitations otherwise set forth in section 222 will apply to Anthem regardless of any changes that may occur in the particular health plans offered by the Company. See, e.g., 24-A M.R.S.A. § 222 (11-A).
In order that all pertinent statutory standards be met, the Superintendent should require in his Final Approval Order:
In order to fulfill the further specific requirements of §4204(7) and [Redacted – Confidential],
the Commissioner’s Final Order of Approval should further require: 5. That Anthem super parent and upper tier Anthem entities maintain "insolvency insurance", "insolvency reserves" or other adequate protective measures at a level sufficient to assure that hospitals and providers are fully compensated for all benefits they provide to Anthem Maine subscribers and enrollees, notwithstanding the insolvency. 6. That the Superintendent’s Final Order set forth the proper amount or the methodology for calculating that amount, to assure the full insolvency coverage called for under §4204(7). This amount should include, but not be limited to, full financial coverage for:
The statutory provisions authorizing and requiring the preceding 6 standards include: S.C. 3, 24-A M.R.S.A. §222(7)(A)(3); S.C. 4, 24-A M.R.S.A. §222(7)(A(4), S.C. 6, 24-A M.R.S.A. §3476(2)(A); S.C. 8, 24-A M.R.S.A. §222(7)(A)(7); S.C. 9, 24-A M.R.S.A. §3476(2)(A), S.C. 17, 24-A M.R.S.A. §§2301(9-D)(E)(1) and (9-D)(L); S.C. 17, 24 M.R.S.A. §2301(9-D)(E)(9); S.C. 26, 24-A M.R.S.A. §3484(2). III. The Superintendent Must Require Continuation of PIP Payments and Related Contract Provisions and Clean Claims Practices The MHA and its witnesses have also emphasized the importance of the historic BCBSME practice of providing periodic interim payments (PIP), as well as existing BCBSME procedures for defining processing and paying clean claims. The PIP system assures an even level of cash and removes incentives to delay claims and hence to define "clean claims" with excessive or artificial rigor. MHA-5 Kempton-1, page 15-16. Maintenance of these practices is important in order to provide financial stability and predictability to Maine’s rural hospitals, many of which face perilous financial circumstances. These problems are severe and growing. See Exhibits MHA-1, Behre Testimony, MHA-1-Behre-2; MHA-5, Kempton Testimony, pp. 13 through 16, Transcript April 6 Afternoon Public Session, pp. 32-33. [Redacted – Confidential] Given the importance of this issue, and because Anthem Maine would be able to terminate the contracts down the road, with a 90-day no-cause notice, Transcript April 3, Public Afternoon Session at 72, MHA urges that the Final Order make Anthem Maine’s intention more binding and permanent, and require:
These standards and requirements are authorized and necessary pursuant to several Superintendent Criteria, including 24-A M.R.S.A. §222(7)(A)(4) (prejudice policyholder or enrollees) 24-A M.R.S.A. §222(7)(A)(7) (affect adversely… contractual obligations of BCBCME… or their ability and tendency to render service in the future to their policyholders, enrollees and the public …" 24 M.R.S.A. §2301(9-D)-(E)(1) and (9-D)(L) "adversely affect in any manner, the services to be rendered to subscribers…" See also the Superintendent’s Notice of November 4, Issues 4, 8, 10, 17, 26 and statutory references set forth therein. IV. The Superintendent Must Incorporate Explicit Approval Standards Assuring Anthem Maine Will Have and Maintain an Adequate Network of Providers. In colloquy in the course of the hearings, the Superintendent has stated that the global assignment of the existing BCBSME provider network to Anthem Maine will initially satisfy Section 4204, Chapter 850 and Chapter 191 criteria relating to network adequacy, and that Anthem Maine will be required to comply with applicable network adequacy provisions on an ongoing basis. See, e.g., BOI Rule Chapter 850, § 7. More is needed in the Order both to fulfill statutory requirements and to "maintain a high level of positive provider and consumer relations consistent with BCBSME standards for over 60 years, consistent with the policy goals of the MHA Board in its February 22, 2000 vote." supra, p. 1. There is reason for significant concern in the absence of express approval standards and careful ongoing monitoring by the BOI. On the one hand, Anthem Maine’s February 1, 2000 COA filing, Exhibit 3-A, states in the Introductory Statement (website version: BCBSME’s provider networks are the most comprehensive in the state. BCBSME has managed care contracts with 988 primary care physicians, 1370 specialists and all Maine hospitals as well as with skilled nursing facilities, home health agencies, imaging centers and infusion providers. Conversely, in the Sept. 15, 1999 Joint Form A Application, website version, p. 22, the Applicants make the following statement: Anthem BCBSME’s 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 and 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 Maine’s hospitals, there may be opportunities for selective contracting in specific target areas. MHA’s efforts to obtain a reconciliation of these divergent statements from Anthem witnesses were unsuccessful. Absent special Final Approval Order conditions, Anthem Maine may elect to engage in "selective contracting" and thereby determine to reduce substantially its network of community hospitals, so long as it maintains the minimum network adequacy requirements of Chapter 850 and fulfills reporting requirements. Absent the imposition of appropriate controls on Anthem Maine, this stated intention to engage in selective contracting has the potential to dismantle the most expansive network in the state, with resultant significant injury to subscribers, enrollees and consumers throughout the state and the providers serving them. See MHA-4, Peterson Testimony, pp. 11-16; MHA-4-Peterson-1; and MHA-4, Peterson-2. The existing BCBSME provider contracts permit either party to terminate them "without cause" upon 90 days notice. Examination of Mr. Vangeison or McGinty, Transcript, April 3, Public Afternoon Session, p. 72. If Anthem Maine were to use this contract termination language to select out one or more hospitals, the potential for harm to consumer, enrollees and subscribers is very real. Likewise, Anthem Maine’s application does not include a rural "access plan" of its own that fulfills §4204(2)(M). Rather, Anthem’s filing states it "intends" to follow the BCBSME Access Plan already on file with the BOI, but Anthem has not described or formally committed itself to the Plan’s particular elements. To fulfill all pertinent statutory criteria, and to take Anthem up on its assurance that it and Anthem Maine will always fulfill all regulatorily imposed requirements, the MHA urges that the Superintendent incorporate in his Final Order of Approval his affirmative findings of compliance and that the Order require:
24-A M.R.S.A. §4204(2)(M); Chapter 850; S.C.3; 24-A M.R.S.A. §222(7)(A)(3), S.C. 4; 24-A M.R.S.A. §222(7)(A)(4); S.C.10; 24 M.R.S.A. §2301(9-D)(E)(1) and (9-D)(L); S.C. 17, 24 M.R.S.A. §2301(9-D)(E)(5), S.C. 24, 24-A M.R.S.A. §3484(2). V. Anthem Should be Required to Continue to Offer Full Range of Individual and Small Group Products and to Undertake Adequate Marketing of Products. BCBSME has long and justifiably prided itself as the "insurer of last resort". Following reforms to the Maine Insurance Code in the 1990s, other carriers are now compelled to join Blue Cross in these efforts. These reforms have included "guaranteed issue", "guaranteed renewal" and "community rating". Nonetheless, BCBSME has continued to distinguish itself in several respects as to the scope and range of products and the extent to which it marketed these in all parts of the State. See MHA-1, Behre Testimony pp.13-14. While Anthem Maine’s filings state it will step into BCBSME’s shoes for purposes of maintaining its existing product mix, no binding commitments of ongoing future maintenance have been made. Of special concern is continuation and adequate marketing of the Medicare Supplement coverages and individual coverage. [Redacted – Confidential]
The Superintendent has suggested his primary focus for review and approval to be the scope of products Anthem Maine will have in place as of the date it initiates services in Maine. If so, the COA and Form A filings would likely be deemed acceptable. Under the Conversion Statute, however, the Superintendent is directed by the Legislature to evaluate many more factors and to impose a higher standard of review. Accordingly, the Final Approval Order ought to affirmatively require: That Anthem Maine maintain the full BCBSME range of products presently in place and carry out adequate marketing through December 31, 2003 – Anthem Maine may modify benefit features and other provisions of these products so long as the product itself remains available; See S.C.1, S.C.3, S.C.4, S.C.5, S.C.10, S.C.17, S.C.24 and S.C.26 (among others) and statutory references therein.
Conclusion The MHA respectfully urges the Superintendent to issue an appropriate Final Approval Order and any necessary supplemental orders to incorporate each of the preceding proposed provisions and such other and further requirements as he deems necessary under Section 222, Chapter 56, and Chapter 89 of the Insurance Code, 24 M.R.S.A. §2301(9-D), and related provisions of the BCBSME Conversion Statute. Respectfully submitted, DATED: April 14, 2000
______________________________ _____________________________ Sandra L. Parker, Esq. John P. Doyle, Jr., Esq. Attorney for MHA, Inc. Charles F. Dingman, Esq. MHA, Inc. Attorney for MHA, Inc 150 Capitol Street PRETI, FLAHERTY, BELIVEAU, Augusta, Maine 04330 PACHIOS & HALEY, LLC e-mail: sparker@themha.org One City center P.O. Box 9546 Portland, Maine 04112-9546 (207) 791-3000 CERTIFICATE OF SERVICE The undersigned hereby certifies that on April 14, 2000 a copy of MHA, INC.’s CLOSING STATEMENT AND BRIEF was served via hand delivery, regular mail or electronic mail on each of the persons listed below.
Jeffrey M. White, Esq. Catherine R. Connors, Esq. PIERCE ATWOOD Portland, Maine 04101 (207) 791-1100 (Anthem Insurance Companies, Inc ) Robert S. Frank, Esq. HARVEY & FRANK Two City center, Fourth Floor P.O. Box 126 Portland, Maine 04101 (207) 775-1300 e-mail: frank@harveyfrank.com (Blue Cross/Blue Shield of Maine) Judith Chamberlain, Esq. State of Maine Department of the Attorney General 6 State House Station Augusta, Maine 04333-0006 e-mail: judy.chamberlain@state.me.us (Bureau of Insurance) William H. Laubenstein, Esq. State of Maine Department of the Attorney General 6 State House Station Augusta, Maine 04333-0006 e-mail: bill.laubenstein@state.me.us (Office of the Attorney General) Gregory A. Brodek, Esq. Duane, Morris & Heckscher, LLP 15 Columbia Street, 4th Floor Bangor, Maine 04401-6355 e-mail: gabrodek@duanemorris.com (Maine Health Alliance)
Joseph P. Ditre, Esq. Consumer Health Law Program One Weston Court, Level One P.O. Box 2490 Augusta, Maine 04338-2490 e-mail: jditre@mainecahc.org (Consumers for Affordable Health Care Foundation/Coalition) Michele M. Garvin, Esq. Ropes & Gray One International Place Boston, Massachusetts 02110-2624 e-mail: Mgarvin@Ropesgray.com (Central Maine Healthcare Corporation; Central Maine Partners Health Plan) Bonnie Post Executive Director of the Maine Ambulatory Care Coalition P.O. Box 390 Manchester, Maine 04351 e-mail: bdpmacc@mint.net (Sacopee Valley Health center, Regional Medical center at Lubec, Eastport Health Care, Inc., and the Maine Ambulatory Care Coalition) John Dieffenbacher-Krall Executive Director Maine People’s Alliance 192 State Street Portland, Maine 04101 e-mail: MPA@gwi.net (Maine People’s Alliance)
Gordon H. Smith, Esq. Maine Medical Association 30 Association Drive P.O. Box 190 Manchester, Maine 04351 e-mail: gsmith@ctel.net (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. General Counsel 465 Congress Street, Suite 600 Portland, Maine 04101-3537 e-mail: quigld@mail.mmc.org (Maine Medical center) Sandra L. Parker, Esq. Attorney for MHA, Inc. 150 Capitol Street Augusta, Maine 04330 e-mail: sparker@themha.org (MHA, Inc.) Kellie P. Miller, M.S. Executive Director Maine Osteopathic Association 693 Western Avenue Manchester, Maine 04351 e-mail: meosteo@mint.net (Maine Osteopathic Association)
DATED: April 14, 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 (207) 791-3000
JPD\G:\MHA\2000\ANTHEM\Closing Brief 0414 nonconfidential.doc (April 14, 2000 2:26 PM) Last Updated: October 1, 2008 |
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