U.S. House of Representatives, Committee on Ways & Means: Hearing by the Subcommittee on Health
Written Testimony of David A. Lipschutz,
Interim President/CEO and Staff Attorney, California Health Advocates
California Health Advocates (CHA) is an independent, non-profit organization dedicated to education and advocacy efforts on behalf of Medicare beneficiaries in California. Separate and apart from the State Health Insurance Program (SHIP), we do this in part by providing support, including technical assistance and training, to the network of California’s Health Insurance Counseling & Advocacy Programs (HICAPs) which offer SHIP services in California. CHA also provides statewide technical training and support to social and legal services agencies and other professionals helping Californians with questions about Medicare. Our experience with Medicare is based in large part on our close work with the HICAPs and other consumer assistance programs that are on the front line assisting Medicare beneficiaries.
Of the various options within the Medicare program to access benefits, we recognize that Medicare Advantage (MA) plans can work for some individuals. Other Medicare beneficiaries, however, are often disadvantaged by joining MA plans for a variety of reasons, including restriction of access to providers (including specialists), out-of-pocket expenses (sometimes greater than Original Medicare), and other barriers to care such as utilization management. Payments to MA plan sponsors and corresponding commissions and bonuses paid to agents combine to foster an epidemic of marketing misconduct; all too often, the best plan for the agent is sold rather than the best plan for the beneficiary.
MA plans are, in theory, supposed to “fill in the gaps” of Original Medicare as well as provide additional benefits. Many plans, however, fail to provide protection against out- of-pocket expenses resulting in a new product – the MA gap plan – that is being sold to fill in expensive gaps in MA plans. In addition, certain beneficiaries can be harmed by joining MA plans – in particular, individuals dually eligible for Medicare and Medicaid – as well as other beneficiaries who are faced with unaffordable out-of-pocket expenses as a result of joining such plans.
It is not our purpose to disparage all MA plans, but to call into question the value we are getting out of MA plans collectively, particularly given the amounts MA plan sponsors are paid over and above the costs to Original Medicare of providing care to similarly-situated beneficiaries. We also question whether informed decision-making is impaired by lack of standardization, and the sheer number of plans combined with countless variations in benefits and cost-sharing that compete for beneficiary attention – particularly PFFS plans – and whether these plans are meeting the needs of all, or even a subset, of beneficiaries.
This written testimony will focus on four areas:
- general issues faced by MA plan enrollees, including plan benefits, cost-sharing, access to providers, trends in retiree coverage, and marketing misconduct;
- new insurance products being sold to fill in the gaps of MA plans;
- the experience of dual eligibles in MA plans; and
- recommendations to address shortcomings of the MA program.
II. GENERAL ISSUES FACED by MEDICARE ADVANTAGE ENROLLEES
Choosing the appropriate Medicare coverage for an individual’s particular circumstances has become tremendously complicated for most Medicare beneficiaries since the enactment of the Medicare Modernization Act of 2003 (MMA). Increased payment to insurance companies has led to a staggering increase in the numbers and types of Medicare Advantage plans. Across the country, Medicare beneficiaries face an unprecedented array of MA products, each with complex benefit variations, and differences in premiums and cost-sharing requirements. These variations tend to confound prospective enrollees, and often obscure the potential for out-of-pocket costs, making it difficult for consumers to compare costs and benefits both between plans and with Original Medicare.
While some individuals do benefit from enrollment in Medicare Advantage plans, it largely depends on an individual’s plan and his/her individual needs. Conversely, others are significantly harmed by enrolling in MA plans. Not only do some people who join MA plans lose and have difficulty re-acquiring their Medigap and retiree plans, but the benefits of MA plans can quickly be erased if health care needs change, and people need care that is more expensive than under Original Medicare.
MA Plan Benefit Packages and Cost-Sharing
Through analysis of the Medicare Advantage marketplace, along with the collective experience of those who counsel Medicare beneficiaries, it is clear that there are serious deficiencies in the benefit packages of many Medicare private health plans. As discussed in a September 2007 report by California Health Advocates and the Medicare Rights Center, MA plan shortcomings include:
- consumers with chronic illness can unknowingly incur widely varying levels of cost-sharing under different plans;
- many MA plans do not provide a limit on enrollees’ annual out-of-pocket expenses for medical services, or they exempt certain services (such as chemotherapy) from such limits; and
- many plans charge the same or higher cost-sharing than Original Medicare for specific, costly services, such as inpatient hospital care, nursing home stays, durable medical equipment and home health care.(1)
Using the great flexibility afforded by Medicare law and regulations, and under the guise of marketplace “innovation,” many plan sponsors design their benefits in such a way that front-loads cost-sharing for the most expensive items, (e.g. hospitalization, skilled nursing facility stays, Part B drugs) – services for which beneficiaries do not have a choice to forego, and are not susceptible to incentives to try other providers (e.g., to see primary care providers rather than specialists) or other treatment options.
Example: A HICAP counselor in Southern California who has extensive experience working with individuals with cancer, reports that most MA plans she deals with are charging at least 20% in cost-sharing for chemotherapy and radiation. Enrollees in these plans who receive cancer treatment often have thousands of dollars in monthly out-of-pocket expenses. Most cancer patients in this situation report that when they signed up with their MA plan they thought the copayments for chemo would be $35-$50. Many tell the counselor that they would rather die than leave their families without any money.(2)
Many individuals who seek or already have Medigap policies enroll in Medicare Advantage plans because they are led to believe that MA plans either function just as Medigap plans do, or even better (some in fact enroll in MA plans believing them to be actual Medigap policies). Conned by slick marketing, new MA plan enrollees often do not understand that they no longer have the same out-of-pocket spending protections that they had in their Medigap policies, are astonished to find that they can no longer see their regular doctors and are hit with high medical bills. Also, unlike Medigap plans, which cannot change benefits year-to-year and are guaranteed renewable, every year MA plan sponsors can change benefits, cost-sharing and premiums, forcing enrollees to reanalyze their benefits annually.
It is well documented that Medicare Advantage plans are paid more than Original Medicare rates, and, as partial justification, plan sponsors often tout “extra benefits” that are being provided to their enrollees. Many of the same plans that charge the same or higher cost-sharing than Original Medicare downplay those costs but heavily promote additional benefits of lesser value, ranging from eyeglasses, hearing aids, gym membership, to a monthly allotment of over the counter pharmacy supplies. From an individual beneficiary’s standpoint, these “extras” can provide limited value when compared with high out-of-pocket costs and problems accessing providers that accompany many plans. From a broader perspective, luring enrollees with “extra benefits” provided now, given that current payment rates are unsustainable, is setting enrollees up for a bait-and-switch scenario down the road if plan benefits are cut (or even the following year, as plans can fundamentally change their benefits annually).
Access to Providers
Unlike Original Medicare, coordinated care plans limit access to designated provider networks. Some who join MA plans are surprised to learn that providers who they had seen for years are not members of the plan’s network, or refuse to accept the plan’s benefits, forcing them to find new providers or get out of the plan when they are able to do so.
The greatest risk of not being able to find a provider, paradoxically, seems to occur with MA Private Fee-for-Service (PFFS) plans that were created, in part, to allow enrollees to access a wide range of providers. Although enrollees can seek care from any provider willing to accept the plan’s terms and conditions, providers who do not have a contract with the plan can decide whether to continue to accept the plan with each visit or treatment. In many cases, PFFS plan enrollees struggle to find providers willing to accept the plan’s terms and conditions. For example, the California Medical Association reports low participation by its members in PFFS plans, and expresses concern that PFFS plan networks are inadequate, particularly for specialty referrals. (3)
Example: Ms. P., an 86-year old dual eligible from Central California, was enrolled in a PFFS plan without her knowledge by an insurance agent who knew she was a dual eligible. She was scheduled to have surgery at a local hospital to treat breathing problems and difficulty swallowing food due to a growth in her throat, but the hospital refused to accept the PFFS plan she was enrolled in.
In addition to individuals who give up a Medigap plan in order to enroll in a Medicare Advantage plan, and have difficulty getting their Medigap plan back, some beneficiaries who have pre-existing retiree coverage are often in danger of losing such coverage when they enroll in a Medicare Advantage plan that does not contract with their retiree plan.
Example: Mr. S., a Northern Californian who is 86 years old, had Medicare, Medi-Cal (Medicaid) and a retiree plan. After several calls from an insurance agent, Mr. S. gave in and allowed the agent into his home. Although the agent was aware that Mr. S. had retiree coverage, she pressured him to enroll in an MA PFFS plan anyway. As a result, he lost his retiree coverage. The local HICAP program is working to try to help him get his retiree plan back.
In contrast with retiree plans that do not coordinate with Medicare Advantage, other employers are increasingly looking to push their retirees into Medicare Advantage plans, leading to access to care issues, as well as strains on the financial viability of the Medicare program for all beneficiaries, not just those in MA plans. There is a growing trend of state and local governments, organizations and corporations attempting to save money by shifting their health care costs to the federal government and enrolling retirees in Medicare Advantage products, particularly Private Fee-for-Service (PFFS) plans.(4) This trend exacerbates the strain on Medicare’s finances already imposed by Medicare Advantage overpayments. The same problems encountered by other PFFS enrollees also confront retirees. Although plan sponsors market PFFS products as “nationwide” because they are not required to use a network, David Fillman of AFSCME notes that this claim is “false”; PFFS plans “limit access to care and choice because significant numbers of doctors and hospitals have refused to accept [the patients enrolled in these plans], especially out-of-state.”(5)
Example: The Center for Medicare Advocacy reports recently hearing from a Michigan retiree who is now living in Orlando, Florida, and can’t find a doctor or hospital that is willing to accept the PFFS plan his former employer forced him into. He reports that his Blue Cross Blue Shield plan is working on the problem, but in the meantime he can’t go to a doctor or hospital.
Consumer advocates, state insurance regulators, Congress and the media have all focused attention on appalling abuses surrounding the sale of Medicare Advantage plans over the last two years that have resulted in substantial harm to the victims of such abuse and financial gain to insurance companies and agents.(6) While much attention has been paid to these abuses, in our view, far too little action has been taken by CMS, which, under the MMA, retains the sole jurisdiction over almost all regulatory issues concerning MA plans. Unfortunately, SHIP programs across the country report that marketing misconduct continues unabated.
We refer the Subcommittee to the resources cited above which address marketing misconduct surrounding the sale of MA plans, including incentives pushing such activity. The following, though, serves as a typical example of marketing misconduct, this one impacting a member of the HICAP family in California earlier this month. Although this example is lengthy, it is illustrative in that it includes a number of the common lies, deceptions and distortions that agents still widely use to con people into joining Medicare Advantage plans.
Example: Ms. T., a dual eligible with limited English proficiency living in California’s Central Valley, received a call from an insurance agent claiming to be from the “health department” and said she wanted to come by and “check up” on her. Ms. T. asked her daughter, who works for a local HICAP program, to be present when the agent visited her home in early February 2008. The agent arrived wearing a badge that appeared very similar to a Medicare card, with the agent’s name handwritten on it, and declared that she was “from Medicare.” The agent lied that she was not an agent, and was not there to sell anything, but simply wanted to go over Medicare issues. The agent explained that Ms. T. has Medicare Parts A, B, and D, so now she needed to enroll in Part C. She stated that Part C “works with Medicare together” and she would have no copays. She stated that when “you go to the doctor, you show your Medicare and Medi-Cal card, but when you go to a doctor that doesn’t accept Medi-Cal, you would show your Medicare Advantage card – all 3 cards work together.” She added that “you do know that Medicare and Medi-Cal won’t cover nursing homes, so you need to enroll in Part C right away – you shouldn’t be long, you shouldn’t be without coverage.” When the agent pulled out an MA application, Ms. T’s daughter declined, but asked the agent to leave information. The agent refused to leave marketing material, stating that she only had one copy, but left her business card, indicating that she was indeed a broker selling MA products. Since Ms. T.’s daughter works for a local HICAP, she realized that just about everything said by the agent was a lie or deception at best, and prevented her mother’s enrollment in this plan. The vast majority of Medicare beneficiaries do not have such accessible help when targeted by unscrupulous agents.
Despite the claims of the insurance industry, this is not a matter of “rogue agents” or a “few bad apples” – we are convinced that the payment incentives to plans, and, in turn, the commissions and bonuses paid to agents, drive this type of abuse. While states retain jurisdiction over agents selling Medicare plans, they lack authority to punish the plans for a range of misbehavior, including actions performed by agents selling their products. While a few MA plans have received nominal fines, enrollment suspensions and other more severe punitive measures are rarely meted out by CMS. As discussed below, in our experience, the most severe and prevalent marketing abuses continue to concern the sale of Private Fee-for-Service plans to dual eligibles.
III. MEDICARE ADVANTAGE “GAP” PRODUCTS
The insurance industry and CMS insist that Medicare Advantage products are a good value for all beneficiaries, in terms of “extra” benefits offered and out-of-pocket savings when compared with the Original Medicare program. Despite these assurances, however, significant fissures in MA plans have led to the emergence of a new insurance product aimed at “filling” those gaps. This product, sometimes called “Advantage Plus”, is being marketed by plan sponsors to insurance agents as a “wrap-around plan” that is “designed to fill in the gaps in Medicare Advantage Plans.”(7)
These limited-benefit plans bundle a collection of insurance products, such as hospital indemnity plans and other piecemeal coverage, and pay cash benefits directly to enrollees of MA plans to cover out-of-pocket costs imposed by their MA plan. They are designed specifically to address high out-of-pocket expenses charged by many MA plans for vital services such as inpatient hospital care, skilled nursing facility stays, durable medical equipment and cancer/chemotherapy drugs covered under Medicare Part B.
Companies offering these products encourage insurance agents to sell these “gap” plans alongside Medicare Advantage products. For example, one flyer directed towards agents boasts: “If selling Medicare Advantage Plans, be sure to check out our Wrap Around product section. Easily add an additional 50% in commissions to each Medicare Advantage Sale. Plan can be sold all year long!!” Anecdotally, we have heard of agents encouraging MA enrollees who get a Part B premium rebate through their plan to apply those savings towards purchasing one of these gap products.
The sale and promotion of these products exacerbates the confusion in the Medicare marketplace generated by enormous numbers of MA and Part D plans with multiple and complex plan designs. Further, we believe that the existence of these plans is a symptom of a more widespread disease afflicting the Medicare Advantage program, and underscores how far too many MA plans impose high cost-sharing while providing inadequate benefits. Part of the promise of allowing private insurance companies to offer plans within the Medicare program was that they could provide better benefits, more efficiently, for less money to both beneficiaries and the Medicare program. These gap products, though, that are sold to fill in gaps in coverage that MA plans are failing to fill themselves, starkly highlight the failures of the MA program to achieve these goals.
IV. DUAL ELIGIBLES and MEDICARE ADVANTAGE PLANS
Individuals who are dually eligible for Medicare and Medicaid are entitled to a broad range of benefits provided by both programs. This population, many of whom have significant and complex health needs and generally a lower level of health literacy, rely on overlapping coverage and payment through the Original Medicare program as primary payer and Medicaid as additional coverage. Many MA plans find dual eligibles to be attractive targets due to their right to enroll in and disenroll from plans on a monthly basis, allowing plans to “poach” enrollees from one another, and also because capitated payments to plans are generally higher for dual eligibles.
Enrollment into a Medicare Advantage plan, though, can create problems for dual eligibles not encountered in the Original Medicare program, such as access to care (due to problems accessing providers and utilization management techniques) and greater out-of-pocket expenses. The issue of whether a state Medicaid program is obligated to pay the Medicare cost-sharing for dual eligibles enrolled in MA plans is a complicated one, and includes factors such as a “dual eligible’s coverage category, the type of cost-sharing, the options elected by the State, and payment limitations specified in the State Plan.”(8) In short, practically speaking, it appears that many states do not pay MA cost-sharing for duals in their state, and, as a result, dual eligibles are often charged these amounts. In addition to MA cost-sharing, some duals have to pay premiums for MA plans for coverage that is no different and sometimes worse than under Medicaid.
Certain MA plans – Special Needs Plans (SNPs), are – in theory – designed to address the needs of dual eligibles, although it questionable how well many SNPs perform in this regard. Other MA plans, notably Private Fee-for-Service (PFFS) plans, are generally ill-suited to address the complex needs of dual eligibles, and often cause significant harm to this vulnerable population.
Special Needs Plans (SNPs)
The Medicare Modernization Act (MMA) authorized Medicare Advantage Special Needs Plans (SNPs) that can be designed to provide coverage for certain designated populations: dual eligibles; individuals who are institutionalized; and individuals with chronic and disabling conditions. Since 2006, enrollment in SNPs has increased exponentially, however many dual eligibles – most of whom did not seek out a SNP on their own but were automatically enrolled into one – have experienced significant problems with accessing care and coordinating coverage and payment with state Medicaid programs.
While SNPs present the opportunity for better care coordination, integration and targeted care management, there are no formal requirements set out in law, regulation or CMS guidance that SNPs actually deliver these goals. In the words of one advocate with significant experience assisting dual eligible clients who encounter problems with their SNPs, “[a]bsent minimum standards for meeting the special needs of the populations they serve, labeling these plans as specially designed to do so is misleading.”(9)
Private Fee-for-Service (PFFS) Plans
While SNPs are designed to address the needs of dual eligibles (at least in theory), other Medicare Advantage plans enroll dual eligibles and even seek them out, even though enrollment in many plans appears to offer little tangible benefit, if any, and often leads to significant problems. Over the last two years, we continue to see a disturbing trend of PFFS plan sponsors and their contracting agents marketing PFFS plans to dual eligibles. In many cases, dual eligibles have been left worse off due to access to care issues (including loss of access to providers) and increased out-of-pocket costs.(10)
In our experience, some of the worst and most widespread marketing violations have involved dual eligibles who are sold PFFS plans. Information about the suitability of MA plans for dual eligibles, including meaningful comparisons with Medicaid benefits already available to them, is not made available by the plans or is misleading, and, at best, glossed over during sales pitches.
Example: Mr. C., age 74, is a California dual eligible who is very ill and dependent on oxygen. He was visited by an insurance agent recently who pushed him to enroll in an MA PFFS plan. The agent touted it as a plan “just for people on Medi-Cal.” As a result of his enrollment, Mr. C. is now being billed for services he did not previously have to pay for, including about $4,000 from a durable medical equipment provider who was not paid by the plan. The local HICAP is assisting him with his enrollment and billing issues.
Dual eligibles are being targeted and convinced to enroll in PFFS plans based upon “extra” benefits that agents and plans say will save them money. Duals are often enticed by $20 over the counter benefits, and “extra” hearing, vision and dental coverage, without regard to individual states’ actual Medicaid benefits that they might already be entitled to.
Once enrolled, however, duals often find that their doctors won’t take their PFFS plan. If their primary doctor does take the plan many still find that they are charged for doctors’ visit copays, wheelchairs, walkers and other services and items they did not previously have to pay for. A large portion of duals encounter difficulty finding specialists who will agree to accept their plan. When HICAP programs try to help dual eligibles get out of plans that are not appropriate for them and untangle resulting complex billing issues, some beneficiaries are subject to harassing calls from agents upset that they are losing out on their commissions.
At least one PFFS plan sponsor acknowledges that this plan type is not appropriate for dual eligibles. During a Congressional hearing wherein his company was criticized for the conduct of an agent selling his PFFS plan to dual eligibles, Coventry Vice President Francis Soistman admitted that “…PFFS plans may not be suitable for dual eligibles.”(11)
Other plans, however, hold themselves out as specially catering to duals – notably WellCare Duet PFFS plans. When asked about the appropriateness of PFFS plans targeting dual eligibles for enrollment, a CMS official replied at a hearing before this Subcommittee that Medicare Advantage “is a market-based program and dual-eligibles, like everyone else, have the option of choosing how they wish to obtain services and where they wish to be enrolled.”(12)
California Health Advocates, as well as a number of other beneficiary advocacy groups, has offered several recommendations for curing some of the current problems faced by Medicare Advantage enrollees.(13) We recognize – and appreciate – that the Children’s Health and Medicare Protection (CHAMP) Act of 2007, passed by the House last August, addressed a number of these issues, and we are disappointed that it did not become law. Our recommendations range from broad changes to the structure and financing of Medicare Advantage, to specific proposals that can be implemented by CMS as the federal regulator of these plans. In short, these recommendations include:
- Create standard benefit packages for Medicare Advantage and Part D plans, including:
- Establish no more than two annual limits for out-of-pocket costs
- Prohibit separate cost-sharing for individual Part B services
- Require that MA plans charge no more cost-sharing for services than what is charged under Original Medicare
- Limit the number of plans offered in a given geographic area
- Apply the standardization and simplification requirements of the National Association of Insurance Regulators (NAIC) Medigap Model Act and Regulation to all Medicare Advantage (and Part D) plans
- These requirements should include loss ratio standards, guaranteed renewability requirements, suitability requirements and other consumer protections
- Rescind the statutory preemption that prevents states from enforcing state laws on consumer protections and the marketing of insurance products
- Neutralize payment between Original Medicare and the MA program (see, e.g., recommendations from MedPAC) and use the current excess payments to strengthen access to benefits in other areas of Medicare, such as expanding eligibility for the Medicare Savings Programs and the Part D Low-Income Subsidy
- Ban the sale of PFFS and other MA products to dual eligibles unless plans can prove they offer meaningfully better and more comprehensive benefits than those available through state Medicaid programs, and that enrollees will not face diminished access to providers and/or new out-of-pocket expenses
- Authorize NAIC to develop nationwide marketing guidelines, including:
- Provisions that hold plans more accountable for the actions of agents selling their plan
- Prohibit plans from offering differential commissions based on what type of plan is selected by the enrollee
- Prohibit agents from selling unrelated products
- Develop more comprehensive disclosure documents with clear explanations about how certain choices can impact access to providers and other types of insurance coverage (e.g., retiree, Medigap, Medicaid)
- Exclude plan sponsors culpable of egregious marketing and other violations from participating in the Medicare program for at least two years (similar to rules that apply to certain providers)
While some Medicare Advantage plans do provide value for enrollees, we need to question the value provided by all MA plans – considering the sheer number of plans, variation in benefits and cost-sharing and the fact that the majority of Medicare beneficiaries in the Original Medicare program are subsidizing the extra payments meant to enrich the minority of beneficiaries enrolled in MA plans. Medicare Advantage is not the panacea for perceived shortcomings of Original Medicare, and, in many cases, can be to the detriment of enrollees, particularly the most vulnerable among us. At a time when MA plans are overpaid but many are providing inadequate coverage, Congress should carefully scrutinize the MA program that threatens the stability and integrity of the entire Medicare program.
Thank you for the opportunity to provide these comments.
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- See California Health Advocates and Medicare Rights Center report “Informed Choice: The Case for Standardizing and Simplifying Medicare Private Health Plans (September 2007).
- Also see an article in California Health Advocates’ August 2006 online newsletter re: chemo copays for cancer patients and the trend in MA plans towards charging full Part B cost-sharing vs. flat copays.
- Correspondence between California Health Advocates and the California Medical Association, February 2008
- See, e.g., “Medicare Trend Raises Eyebrows” by Ricardo Alonso-Zaldivar, Los Angeles Times, 2/11/08
- Testimony of David Fillman, AFSCME, before the Senate Finance Committee on 1/30/08: download PDF
- See, e.g. issue briefs written by California Health Advocates and the Medicare Rights Center entitled “After the Gold Rush: The Marketing of Medicare Advantage and Part D Plans” (January 2007) and “The Reluctant Regulator: Centers for Medicare and Medicaid Services’ Response to Marketing Misconduct by Medicare Advantage Plans” (July 2007); also see California Health Advocates’ testimony before this Subcommittee on May 22, 2007 and before the House Energy & Commerce Subcommittee on Oversight & Investigations on June 26, 2007. All of these documents are available at:https://www.cahealthadvocates.org/advocacy/
- See a recent issue brief on this topic written by California Health Advocates entitled “There’s a Hole in the Bucket: New “Gap” Product Being Sold to Fill-in Medicare Advantage Deficiencies” (November 2007)
- June 11, 2007 Memorandum from CMS, Center for Medicaid and State Operations, Disabled and Elderly Health Programs Group to All Associate Regional Administrators, Division of Medicaid and Children’s Health re: Medicaid Obligations for Cost-Sharing in Medicare Part C Plans; also see Center for Medicare Advocacy’s May 31, 2007 Weekly Alert entitled “Medicare Cost-Sharing in Medicare Advantage Plans: Who Pays for Dual Eligibles?”: download PDF
- Alissa E. Halperin, Managing Attorney, Pennsylvania Health Law Project, author of a paper for the Center for Medicare Advocacy entitled “Medicare Advantage Special Needs Plans: A Beneficiary Perspective” (October 2007); also see, generally, Center for Medicare Advocacy’s Special Needs Plan Conference materials (October 2007).
- See, e.g., CHA’s prior testimony before this Subcommittee on May 22, 2007 re: PFFS plans
- Testimony of Francis S. Soistman, Jr., Executive Vice President, Coventry Health Care, Inc., before House Energy & Commerce Subcommittee on Oversight & Investigations, June 2007, available at: download PDF.
- Testimony of Abby Block, Director of Division of Beneficiary Choices, CMS, May 22nd, 2007
- See, e.g., documents cited in footnotes 1 and 6, infra, as well as CHA’s testimony before the National Association of Insurance Commissioners (NAIC) Senior Issues Task Force – Medicare Private Plans Subgroup, Public Hearing on Regulation of Medicare Private Plans (September 11, 2007), available on the NAIC website.