BILL ANALYSIS                                                                                                                                                                                                    






                                 SENATE HEALTH
                               COMMITTEE ANALYSIS
                        Senator Deborah V. Ortiz, Chair


          BILL NO:       AB 774                                       
          A
          AUTHOR:        Chan                                         
          B
          AMENDED:       June 16, 2005
          HEARING DATE:  June 22, 2005                                
          7
          FISCAL:        Judiciary / Appropriations                   
          7
                                                                      
          4
          CONSULTANT:                                                
          Hansel / ag
                                        

                                     SUBJECT
                                         
                         Hospitals:  self-pay policies

                                     SUMMARY  

          This bill would require hospitals to develop a policy  
          specifying how the hospital will determine financial  
          liability for services rendered to financially qualified  
          patients and self-pay patients, as defined.  Requires each  
          hospital to perform various functions in connection with  
          the hospital self-pay policy, including notifying patients  
          of the policy, and attempting to determine the availability  
          of private or public health insurance coverage for each  
          patient.  Places limits on billing and collection  
          procedures to be followed by hospitals and their billing  
          agents.  Requires hospitals to submit to the Office of  
          Statewide Health Planning and Development a copy of their  
          application for financially qualified patients and a copy  
          of their self-pay policy, eligibility procedures, review  
          process, and procedure for determining self-pay pricing.   
          Authorizes the director of OSHPD to levy civil penalties  
          for violations by a hospital of the above provisions and  
          authorizes the Attorney General to investigate whether a  
          hospital is in compliance with the above provisions and to  
          seek remedies for hospitals it finds are not in compliance.  
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                                     ABSTRACT  

          Existing law:  
          1.Establishes the Office of Statewide Health Planning and  
            Development (OSHPD), which is charged with enforcement of  
            various provisions of law relating to health facilities,  
            including hospitals.  

          2.Requires hospitals to report financial and utilization  
            data to OSHPD in accordance with procedures and forms  
            established by OSHPD.  

          3.Requires every private, non-profit hospital to submit  
            annually to OSHPD a community benefits plan that details  
            how the hospital identifies and addresses community needs  
            within the hospital's service area.  

          4.Provides that a community benefits plan may include:  (a)  
            a description of the health care services rendered to  
            uninsured, underinsured, and individuals eligible for  
            public programs, (b) a description of other services  
            rendered to the community, such as health promotion,  
            medical research and medical education, and (c) an  
            accounting of the cost of providing these services.  
          
          This bill:  
          1.Requires each hospital to develop a policy specifying how  
            the hospital will determine the financial liability for  
            services rendered to financially qualified patients and  
            self-pay patients.  

          2.Defines, for purposes of the bill, financially qualified  
            patients as those who have family incomes at or below 400  
            percent of the federal poverty level and who either do  
            not have third party coverage from a health plan,  
            Medicare, or Medicaid and whose injury is not compensable  
            under workers compensation, automobile or other  
            insurance; or are insured but whose deductibles,  
            copayments, medical, or hospital bills after payment by  
            third party payers exceed five percent of their annual  
            income or a lower level if established by the hospital's  
            charity care policy.  
                                                           
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          3.Requires each hospital's policy to specify how it will  
            determine and apply allowances for services provided to  
            financially qualified patients.  Requires the allowance,  
            at a minimum, to be equal to the difference between the  
            charge for the services set forth in the hospital's  
            established charge schedule and the greater of the  
            payments the hospital would receive from the Medicare  
            Program, the Medicaid Program, or workers' compensation.   


          4.Requires each hospital to include in its policy a section  
            addressing charity care patients.  Requires the charity  
            care section to specify the financial criteria and the  
            procedure used by the hospital to determine whether a  
            patient is eligible for charity care.  Permits the  
            hospital to specify that no persons are eligible for  
            charity care under any circumstances.  

          6.Requires each hospital to provide patients with oral and  
            written notice of the hospital's policy for financially  
            qualified and self-pay patients at the time of admission  
            and discharge, as specified.  

          7.Requires notice of the hospital's policy for financially  
            qualified and self-pay patients to be clearly and  
            conspicuously posted in locations that are visible to the  
            public, including, but not limited to, the emergency  
            department, if any; the billing office; the admissions  
            office;  and any other locations that may be determined  
            by OSHPD.  

          8.Requires each hospital to submit to OSHPD a copy of the  
            application for financially qualified patients used by  
            the hospital, including the charity care section of that  
            application.  Permits OSHPD, in consultation with  
            interested parties, to develop a uniform self-pay  
            application to be used by all hospitals, as specified.  

          9.Requires each hospital to make all reasonable efforts to  
            obtain from the patient, or his or her representative,  
            information about whether private or public health  
            insurance or sponsorship may fully or partially cover the  
            charges for care rendered by the hospital to a patient,  
                                                           
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            as specified.  

          10.Requires the hospital, if it bills a patient who has not  
            provided proof of coverage by a third party at the time  
            the care is provided or upon discharge, to provide to the  
            patient as a part of that billing a clear and conspicuous  
            notice that includes all of the following:  
             a.   A statement of charges for services rendered by the  
               hospital;  

             b.   A request that the patient inform the hospital if  
               the patient has health insurance coverage, Medicare,  
               HF, Medi-Cal, or other coverage;  

             c.   A statement that if the consumer does not have  
               health insurance coverage, that they may be eligible  
               for Medicare, HF, Medi-Cal, CCS, or charity care;  

             d.   A statement indicating how patients may obtain  
               applications for Medi-Cal and HF and that the hospital  
               will provide these applications on request.  

             e.   Information regarding the financially qualified  
               patient and charity care application, including the  
               hospital contact for resources for additional  
               information regarding charity care and a statement  
               indicating how patients may obtain an application for  
               a financially qualified patient, as specified.  

          11. In order to facilitate payment by public or private  
            third party payers, limits the allowable debt collection  
            activities of hospitals or their assignees, including  
            collection agencies or billing services, for at least 180  
            days after discharge or after the final day service is  
            provided, to the following activities:  
             a.   Sending a bill to the patient in accordance with  
               existing law;  

             b.   Attempting to negotiate payment of the bill or a  
               payment plan in accordance with this article;  

             c.   Attempting to collect payment from any responsible  
               third-party payer, either public or private;  

                                                           
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             d.   Providing any information that may assist the  
               patient in obtaining coverage through Medi-Cal or HF,  
               or any other public program for which the patient may  
               be eligible;  

             e.   Attempting to make a final determination as to  
               whether the patient may be considered a self-pay  
               patient under the hospital's self-pay policy or is  
               eligible for charity care under the hospital's charity  
               care policy.  

             f.   Assisting a financially qualified patient in  
               obtaining the allowance for services required by the  
               bill and assisting the patient in applying for the  
               hospital's charity care policy, if any.  

             g.   Providing any notices required under state or  
               federal law.  

          12.Requires a hospital, its assignee, collection agency, or  
            billing service to use reasonable efforts to negotiate a  
            payment plan, as defined, unless the patient has  
            requested that the hospital, its assignee, collection  
            agency, or agent not contact the patient.

          13.Permits the hospital, its assignee, collection agency,  
            or billing service, after the time period specified in  
            #11 above has elapsed, to engage in any other debt  
            collection activities otherwise permitted by law,  
            including, but not limited to, reporting adverse  
            information to a consumer credit reporting agency or  
            commencing civil action against the patient for  
            nonpayment.  

          14.Prohibits a hospital, its agent, collection agency, or  
            assignee from using wage garnishment or a lien on a  
            primary residence as a means of debt collection from a  
            financially qualified patient.  

          15.Requires the period described in #11 above to be  
            extended if the patient has a pending appeal, as  
            specified, for coverage of the services.  

          16.Requires the hospital, any assignee of the hospital, or  
                                                           
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            other owner of the patient debt, including a collection  
            agency, prior to commencing collection activities against  
            a patient, to provide the patient with a clear and  
            conspicuous written notice containing information about  
            nonprofit credit counseling services in the area and a  
            plain language summary of the patient's rights pursuant  
            to this bill, the Rosenthal Fair Debt Collection  
            Practices Act, and the federal Fair Debt Collection  
            Practices Act, as specified.  

          17.Requires each hospital to provide to OSHPD, in a format  
            determined by OSHPD, a copy of its self-pay policy,  
            eligibility procedures, review process, and procedure for  
            determining self-pay pricing.  Requires the information  
            to be provided at least biennially on January 1, or when  
            a significant change is made.  

          18.Permits, after appropriate notice and opportunity for  
            hearing, the Director of OSHPD to levy civil penalties  
            for violations of this bill as follows:  
             a.   A hospital that violates any provision of this  
               bill, except for provisions pertaining to required  
               allowances for financially qualified patients, is  
               liable for civil penalties of not more than $500 per  
               day per patient affected for each violation;  

             b.   A hospital that bills a patient for amounts in  
               excess of the allowances required by the bill is  
               liable for a civil penalty of three times the amount  
               billed in error to the patient;  

             c.   Allows the Director, in lieu of civil penalties, to  
               require the hospital to provide care at no cost to  
               financially qualify persons in a value comparable to  
               three times the value of the care provided in  
               violation of provisions of the bill dealing with  
               allowances for financially qualified patients;  and,  

             d.   Allows the Director to require the hospital to  
               provide notice to the public of its policy regarding  
               financial liability for services to financially  
               qualified and self-pay patients.  
          19.Permits the Attorney General to authorize an  
            investigation, as specified, to determine whether a  
                                                           
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            hospital is complying with the bill and authorizes the  
            Attorney General to seek to recover:
             a.   Actual damages;

             b.   Civil penalties of not more than $500 per day for  
               each violation;

             c.   For a violation of provisions dealing with required  
               payment allowances for financially qualified patients,  
               three times the amount billed to the patient;

             d.   For intentional or willful violations of the  
               provisions of the bill, exemplary damages, in an  
               amount the court deems proper;

             e.   Equitable relief as the court deems proper; and,  

             f.   Reasonable attorneys' fees and court costs.  

          20.Prohibits anything in this bill from being construed to  
            prohibit a hospital from uniformly imposing charges from  
            its established charge schedule or published rates, nor  
            preclude the recognition of a hospital's established  
            charge schedule or published rates for the Medi-Cal  
            program and the Medicare Program reimbursement charges.  

          21.Prohibits the amounts paid by patients for services  
            resulting from the self-pay allowances or charity care  
            arrangements that are applied under a hospital's self-pay  
            and charity care policies from constituting a hospital's  
            uniform, published, prevailing, or customary charges, its  
            usual fees to the general public, or its charges to  
            non-Medi-Cal purchasers under comparable circumstances,  
            for purposes of any payment limit under federal Medicaid  
            law, Medi-Cal law, or any other federal or state-financed  
            health care program.  

          22.Requires, to the extent that this bill results in a  
            federal determination that a hospital's established  
            charge schedule or published rates are not the hospital's  
            customary or prevailing charges for services, the  
            requirement in question to be inoperative with respect to  
            a hospital that is licensed to and operated by a county  
            or a hospital authority, as specified.  
                                                           
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                                  FISCAL IMPACT  

          According to the Assembly Appropriations Committee:
          1.One-time special fund cost (Health Data Fund) OSHPD of  
            $106,000 beginning in 2005-06, and on-going special fund  
            costs of approximately $375,000.  

          2.Indeterminate but significant on-going General Fund (GF)  
            costs to University of California (UC) hospitals and to  
            state-funded health care programs, likely in the tens of  
            millions of dollars annually.  By limiting the amount  
            hospitals can charge certain self-pay patients and  
            delaying referral to collection, these costs could be  
            shifted to other payers, including the State of  
            California, which purchases coverage for state employees  
            and retirees through CalPERS, and pays one third to one  
            half of the costs of the over 7 million individuals  
            enrolled in the Medi-Cal and Healthy Families Programs.  

                            BACKGROUND AND DISCUSSION  

          According to the author, there is no current law regarding  
          the prices that uninsured and underinsured consumers pay  
          for health care or regarding collection practices for  
          health care debt.  The author points to a February 2005  
          study published in the journal Health Affairs which  
          surveyed 1,771 personal bankruptcy filers and which found  
          that about half cited medical causes for their bankruptcy.   
          The study found that among those whose illnesses led to  
          bankruptcy, out-of-pocket costs averaged $11,854 since the  
          start of illness, and that medical debtors were 42 percent  
          more likely than other debtors to experience lapses in  
          health insurance coverage.  The author asserts that  
          requiring hospitals to develop and disseminate policies on  
          payment allowances and to provide payment allowances are  
          modest steps to protect low-income uninsured and  
          underinsured patients when they experience a need for  
          hospital services.  

          In February 2004, the California Healthcare Association  
          (CHA) issued voluntary guidelines to protect consumers from  
          hospital overcharging.  The document stated that regulatory  
          reform is needed to enable hospitals to effectively respond  
                                                           
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          to the individual needs of low-income uninsured patients  
          and that CHA anticipates that the United States Department  
          of Health and Human Services will provide guidance on how  
          hospitals can appropriately bill the uninsured. In the  
          meantime, CHA urged its member hospitals to adopt the  
          voluntary principles and guidelines to better meet the  
          needs of patients who cannot afford the health care  
          services they receive.  The guidelines encourage hospitals  
          to do a number of things with regards to low-income,  
          uninsured patients, including:  
          1.Ensuring that financial assistance policies clearly state  
            the eligibility criteria (i.e., income, assets) and the  
            process used to determine whether a patient is eligible  
            for financial assistance.  

          2.Limiting expected payments from patients eligible for  
            financial assistance to amounts that do not exceed the  
            payment the hospital would receive from Medicare, other  
            government sponsored health programs, or as otherwise  
            deemed appropriate by the hospital.  

          3.Having written policies about when and under whose  
            authority patient debt is advanced for collection, and  
            using the hospital's best efforts to ensure that patient  
            accounts are processed fairly and consistently.  

          4.Posting notices regarding the availability of financial  
            assistance to low-income uninsured patients in visible  
            locations throughout the hospital, such as  
            admitting/registration, billing office, emergency  
            department, and other outpatient settings.  

          5.Sharing financial assistance policies with appropriate  
            community health and health services agencies and other  
            organizations that assist such patients.  

          6.Attempting to communicate with patients in their primary  
            language when discussing the hospitals financial  
            assistance policies; and ensure that staff are  
            knowledgeable about the existence of the hospital's  
            financial assistance policies.  

          In the 2003 - 04 Session the Legislature passed SB 379  
          (Ortiz), which would have required hospitals to develop,  
                                                           
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          post, and disseminate charity care and reduced payment  
          policies, and would have limited allowable charges for  
          patients with incomes below 400 percent of the federal  
          poverty to the greater of Medicare, Medicaid, or workers  
          compensation payment amounts.  In vetoing the bill, the  
          Governor stated:  

               "Recently, the hospital community voluntarily adopted  
               guidelines to
               assist low-income uninsured Californians who receive  
               services at a
               hospital but cannot afford to pay the bill in full.   
               At a minimum,
               these guidelines allow patients who are at or below  
               300 percent of the
               federal poverty level to apply to the hospital for  
               financial
               assistance.  Additionally, the guidelines limit the  
               costs of
               procedures to reflect the prices paid by government  
               payers, require
               hospitals to post their financial assistance policies  
               and their
               eligibility criteria and encourage hospitals to help  
               eligible
               patients apply for public health programs.  By choice,  
               many hospital
               systems have adopted guidelines that exceed the  
               aforementioned
               minimum standards adopted by the hospital community,  
               further
               protecting patients at risk of financial harm.  

               I recognize the proponents desire to assist self-pay  
               patients with
               large hospital bills by requiring price discounts but  
               I also
               recognize that the hospital community took a  
               significant step in
               adopting these guidelines, especially those hospitals  
               that are
               struggling financially themselves.  Ultimately, I  
               decided that the
               voluntary guidelines must be given time to be  
                                                           
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               implemented and
               reviewed."

          Arguments in support  
          According to supporters, hospitals must stabilize any  
          patient who needs emergency care, but hospitals can and do  
          charge uninsured and underinsured patients the highest  
          prices for services they provide.  Hospitals report that  
          they spend about one percent of their patient revenue on  
          charity care, but hospitals are not required to disclose  
          the circumstances under which a patient may qualify for  
          free care.  Supporters further argue that sending patients  
          to collections 30 to 60 days after they receive care puts  
          the credit rating of patients at risk if insurers fail to  
          pay within that timeframe.  For uninsured patients, 30 - 60  
          days does not provide adequate time to arrange their  
          finances in order to make payments on their bills.   
          Although the major hospital associations and systems have  
          adopted voluntary guidelines for providing charity and  
          reduce price care, nothing requires them to comply with the  
          guidelines.  Supporters further argue that the bill  
          protects self-pay patients from being charged more than  
          insured patients and reduces the chances that hospital  
          costs result in personal bankruptcy and is therefore an  
          important step in improving the equity of California's  
                                                                            health care system.  Supporters finally argue that the bill  
          provides necessary protections to ensure that uninsured and  
          underinsured patients are not discouraged from seeking  
          hospital services when they need them.  
          Arguments in opposition  
          Opponents argue that although this bill incorporates many  
          of the provisions of the hospital industry's voluntary  
          guidelines for providing charity and reduced price care,  
          the guidelines provide necessary flexibility for hospitals  
          to tailor their policies to account for the characteristics  
          of their patient populations and resources.  In particular,  
          hospitals need flexibility to determine whether they can  
          offer charity and reduced price care to patients with  
          incomes in excess of 300 percent of the federal poverty  
          level, the level required under CHA's guidelines.   
          Opponents also argue that this bill unfairly places the  
          burden of a dysfunctional healthcare system on hospitals,  
          which provide care to anyone who need help and operate  
          emergency rooms and trauma centers around the clock.   
                                                           
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          Opponents further argue that the bill imposes rigid and  
          punitive requirements on hospitals to provide free care  
          without addressing any of the underlying factors that  
          created the growing problem of the uninsured in the first  
          place.  Opponents further point out that hospitals face  
          numerous unfunded mandates and that this bill will make it  
          increasingly difficult to provide care and operate  
          emergency rooms and trauma centers to serve those who need  
          help.  The University of California argues that this bill  
          creates a new public benefit for a sizable population who  
          may have some ability to pay for services rendered or  
          otherwise afford health insurance coverage and contends  
          that they already have an established commitment to provide  
          free care and payment assistance to a disproportionate  
          share of the state's uninsured patients.  The California  
          Association of Collectors opposes provisions of the bill  
          that impose a blanket prohibition on the use of wage  
          garnishments or liens to obtain payment of hospital bills  
          irrespective of the debtor's ability to pay the debt, and  
          states that existing requirements governing the use of wage  
          garnishments and judgment liens provide substantial  
          consumer protections to debtors.  

          Related Bills
           SB 24 (Ortiz) -- Requires hospitals to develop, post, and  
            disseminate charity care and reduced payment policies for  
            hospitals, and limit allowable charges for patients with  
            incomes below 400 percent of the federal poverty to the  
            greater of Medicare, Medicaid, or workers compensation  
            payment amounts, and requires non-profit hospitals to  
            provide a minimum threshold of charity care.  Currently  
            in Senate Appropriations Committee.  

          Previous legislation  
           SB 379 (Ortiz) of 2003-04 Session -- Effective June 1,  
            2005, would have required hospitals to develop, post, and  
            disseminate charity care and reduced payment policies,  
            which include minimum eligibility requirements of 400  
            percent of the federal poverty level, limitations on  
            expected payments from qualified patients, and limits on  
            billing and collection activities.  Vetoed by Governor.

           AB 232 (Chan) of 2003-04 Session -- Would have required  
            each hospital to develop a self-pay policy specifying how  
                                                           
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            the hospital determines prices to be paid by self-pay  
            patients, as defined, and limits these prices for  
            patients below specified income levels.  Would have  
            established limits on billing and collection activities  
            of hospitals and their agents.  Died on Senate floor.  

           SB 1394 (Ortiz) of 2001-02 Session -- Would have required  
            hospitals to establish and publicize charity care  
            policies and established a reduced payment schedule for  
            uninsured and underinsured persons.  Would have limited  
            collections and billing activities of hospitals for 120  
            days following discharge.  Died on Senate floor.

                              COMMENTS AND QUESTIONS
           
          1.Similarity to other bills heard by Health Committee.  AB  
            774 is similar to SB 24 (Ortiz) which was heard by the  
            Committee on March 30, and to SB 379 (Ortiz) and AB 232  
            (Chan), heard by the committee in the 2003-04 session.   
            SB 379 would have required hospitals to develop and post  
            charity care and reduced payment policies and placed  
            limits on allowable charges and collection practices for  
            persons eligible to receive charity care or payment  
            allowances, similar to this bill; however, the bill was  
            vetoed by the Governor.  SB 24 (Ortiz), as it was heard  
            by the committee, contains additional provisions  
            requiring nonprofit hospitals, as a condition of  
            maintaining their tax exempt status, to demonstrate  
            compliance with the provisions of the bill dealing with  
            development and posting of charity care and reduced  
            payment policies and limits on charges and collection  
            practices for persons eligible to receive charity care or  
            payment allowances.  The bill also establishes a minimum  
            threshold for charity care expenditures for nonprofit  
            hospitals.  The bill is currently in Senate  
            Appropriations Committee.  







                                                           
          Continued---









          2.Suggested technical amendments.  
             a.   Modify Section 127440 (a) as follows:

          127440.
             (a)   For violations of this article, the director of  
               the office may, after appropriate notice and  
               opportunity for hearing, levy civil penalties as  
               follows: 

             (1)   A hospital that violates any provision of this  
               article, except for subdivision  (c)  (b) of Section  
               127405, shall be liable for civil penalties of not  
               more than five hundred dollars ($500) per day per  
               patient affected for each violation.  

             (2)   A hospital that bills a patient for amounts in  
               excess of those provided for in Section 127405 shall  
               be liable for a civil penalty of three times the  
               amount billed in error to the patient.  

             (3)  In lieu of the civil penalty, require the hospital  
               to provide  care at no cost to financially qualified  
               persons in a value comparable to three times the value  
               of the care provided in violation of Section 127405   
               charity care and reduced payments in an amount equal  
               to three times the difference between the amount  
               billed to financially qualified and self-pay patients  
               and the amount that should have been billed under  
               subdivision (b) of Section 127405.  

             (4)   Require the hospital to provide notice to the  
               public in a newspaper of general distribution of its  
               policies pursuant to this article, of any violations  
               of this act, and of the penalties assessed. 

             (b)   Modify Section 127442 as follows:
          
          Upon a determination that a hospital has violated this  
          article, the  The  Attorney General may seek to recover all  
          of the following:
             (a)   Actual damages.  

             (b)   Civil penalties of not more than five hundred  
               dollars ($500) per day for each violation.  

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             (c)   For a violation of subdivision  (c)  (b) of Section  
               127405, three times the amount billed to the patient.   


             (d)   For intentional or willful violations of this  
               article, exemplary damages, in an amount the court  
               deems proper.  

             (e)   Equitable relief as the court deems proper.  

             (f)   Reasonable attorneys' fees and court costs.  

                                  PRIOR ACTIONS

           Assembly Floor:          43 - 34  Pass
          Assembly Appropriations:   13 - 5  Do Pass
          Assembly Health:           10 - 4  Do Pass

                                    POSITIONS  
                                        
          Support:    Health Access California (sponsor)
                      AARP California
                      American Federation of State, County, and  
                      Municipal Employees
                      Applied Research Center
                      Asian and Pacific Islander American Health  
                      Forum
                      California Acorn
                      California Alliance for Retired Americans
                      California Church Impact
                      California Commission on the Status of Women
                      California Federation of Teachers
                      California Immigrant Welfare Collaborative
                      California Labor Federation
                      California National Organization for Women
                      California Public Interest Research Group
                      Coalition for Community Health
                      Coalition for Humane Immigrant Rights of Los  
                      Angeles
                      Congress of California Seniors
                      Consumer's Union
                      East Bay Alliance for a Sustainable Economy
                      Gray Panthers California 
                      Greenlining Institute
                                                                       
          



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                      Health Care for All - California 
                      Insure the Uninsured Project
                      JERICHO
                      Latino Coalition for a Healthy California
                      Lawyers' Committee for Civil Rights
                      Multicultural Area Health Education Center
                      Screen Actors Guild
                      Santa Cruz Chapter of Healthcare for All
                      United Nurses Association of California/Union  
                      of Health Care   
                                    Professionals
                      Valley Seniors
                      One individual

          Oppose:     Adventist Health
                      Alliance of Catholic Health Care
                      Barlow Respiratory Hospital 
                      Biggs-Gridley Memorial Hospital
                      California Association of Collectors
                      California Hospital Association
                                Catholic Healthcare West
                                Citrus Valley Health Partners
                                Community Hospital of the Monterey  
                    Peninsula
                                Continental Rehabilitation Hospital  
                    of San Diego
                                Lodi Memorial Hospital
                                Loma Linda University Medical Center
                                Mission Hospital
                                Mission Hospital Regional Medical  
                    Center
                                Paradise Valley Hospital
                                Saddleback Memorial Medical Center
                                Salinas Valley Memorial Healthcare  
                    System
                                Seneca Healthcare District
                                St. Jude Medical Center
                                Saint Louise Regional Hospital
                                Scripps Health
                                University of California




                                                                       
          



          STAFF ANALYSIS OF ASSEMBLY BILL 774 (Chan)            Page  
          17


          




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