BILL ANALYSIS                                                                                                                                                                                                    



                                                                  SB 2046
                                                                  Page  1

          Date of Hearing:   June 27, 2000

                            ASSEMBLY COMMITTEE ON HEALTH 
                               Martin Gallegos, Chair
                    SB 2046 (Speier) - As Amended:  June 20, 2000

           SENATE VOTE  :  27-6
           
          SUBJECT  :  Health care: prescription drug coverage.

           SUMMARY  :  Expands a prohibition against health care service  
          plans (health plans) and disability insurers which limits or  
          excludes coverage for a drug that is prescribed for off-label  
          use, by including drugs prescribed to treat chronic and  
          disabling conditions, as specified, in addition to  
          life-threatening conditions.  Specifically,  this bill  :   

          1)Prohibits health plans and disability insurers that cover  
            prescription drugs from limiting or excluding coverage for a  
            drug on the basis that the drug is prescribed for a use that  
            is different from the use for which that drug has been  
            approved for marketing (known as off-label) by the federal  
            Food and Drug Administration (FDA), when the drug is  
            prescribed for the treatment of a chronic and disabling  
            condition and is medically necessary to treat that condition.

          2)Specifies that drugs prescribed for off-label use, in the case  
            of health plans, must be on the health plan's formulary to be  
            protected by this bill, and applies a provision of law  
            requiring health plans to maintain an expeditious process by  
            which prescribing providers may obtain authorization for  
            medically necessary nonformulary drugs, to these off-label  
            drug prescriptions for chronic and disabling or  
            life-threatening conditions.

          3)Defines "chronic and disabling," for purposes of this bill, as  
            either or both of the following:

             a)   Diseases or conditions where the likelihood of  
               interference over an extended period of time with one or  
               more of the activities of daily living is high if left  
               untreated; or
             b)   Diseases or conditions that require ongoing treatment to  
               maintain remission or prevent deterioration in the ability  
               to engage in one or more of the activities of daily living.








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          4)Permits health plans and disability insurers to use a  
            formulary, copayment, technology assessment panel, or similar  
            mechanism, as a means for appropriately controlling the  
            utilization of an off-label drug.

          5)Specifies that if a health plan or insurer denies coverage for  
            off-label drug prescriptions for chronic and disabling or life  
            threatening conditions on the basis that its use is  
            experimental or investigational, the decision is subject to  
            review under the Independent Medical Review System, as  
            specified.




           EXISTING LAW  :

          1)Regulates health plans under the Department of Corporations  
            until June 30, 2000, and under the Department of Managed Care  
            commencing July 1, 2000.  Regulates disability insurers under  
            the Department of Insurance.

          2)Prohibits health plans and disability insurers from limiting  
            or excluding coverage for a drug on the basis that the drug is  
            prescribed for off-label use, provided that all of the  
            following conditions are met:

             a)   The drug is approved by FDA;
             b)   The drug is prescribed by a participating licensed  
               health care professional for the treatment of a  
               life-threatening condition; and
             c)   The drug has been recognized for treatment of that  
               condition by the American Medical Association Drug  
               Evaluations, the American Hospital Formulary Service Drug  
               Information, the United States Pharmacopoeia Dispensing  
               Information, or two articles from major peer reviewed  
               medical journals that present data supporting the proposed  
               off-label use.

          3)Defines "life-threatening," for off label prescription  
            purposes, as diseases or conditions where the likelihood of  
            death is high unless the course of the disease is interrupted,  
            or diseases or conditions with potentially fatal outcomes  
            where the end point of clinical intervention is survival.








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          4)Permits health plans and disability insurers to use reasonable  
            deductible or copayment provisions for off-label drug  
            prescriptions.

           FISCAL EFFECT  :  Unknown

           COMMENTS  :   

           1)PURPOSE OF THIS BILL  .  According to the author, this bill will  
            expand current law that permits the use of prescription drugs  
            for off-label use for the treatment of a life-threatening  
            condition by extending the same coverage to individuals with  
            disabling or chronic diseases.  The author asserts that  
            expanding off-label drug use is essential because it allows  
            patients access to treatment therapies currently not afforded  
            them.  This bill is sponsored by Genentech, Inc., which states  
            that with the tremendous medical advancements experienced in  
            the last decade, in large part through biotechnology, there  
            are a host of medications that are being used to treat  
            diseases and conditions that were not initially contemplated  
            when the drugs were approved.  Genentech states that these  
            off-label uses are not only saving lives but improving the  
            quality of life.  Genentech further asserts that diseases that  
            were once life-threatening, such as HIV, some forms of cancer  
            and cystic fibrosis, are now being controlled with medication  
            to the degree that they no longer meet the definition of  
            life-threatening.  Genentech argues that because of this, some  
            health plans deny access to the very drugs that prevent the  
            condition from being life-threatening.

           2)OFF-LABEL DRUG USE  .  When drugs are approved for use by FDA,  
            they are approved to be marketed for a specific use, often  
            called a "labeled" use.  To meet the high statistical and  
            methodological standards required by FDA for drug approval,  
            drug manufacturers narrowly tailor clinical trials to a  
            specific condition.  While it is not uncommon for  
            manufacturers to be aware that a drug has potential for other  
            uses, the time and expense of obtaining FDA approval often  
            precludes, or at least delays, manufacturers from getting FDA  
            approval for other uses.  However, it is legal for a physician  
            to prescribe a drug for a use other than what the FDA has  
            specifically approved, when the drug is prescribed in  
            accordance with the standards of medical practice.









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           3)SUPPORT  .  The American Cancer Society (ACS) states that it was  
            the co-sponsor of the original legislation regarding off-label  
            drug use for life-threatening conditions, and supports the  
            broadening of this law to include chronic and disabling.  ACS  
            states that it continues to believe that limiting access to  
            "off-label" uses of drugs by refusing to provide financial  
            reimbursement represents an undue financial and emotional  
            strain on patients and may result in unnecessary suffering.   
            The California Medical Association (CMA) supports this bill,  
            stating that the effect of this bill will provide patients  
            with access to off-label drugs for medically necessary  
            conditions under the guidance of a physician when the  
            off-label uses are supported by clinical research.  The CMA  
            asserts that under these circumstances, prompt access to drugs  
            approved by the FDA has both a measure of safety through the  
            specificity of conditions under which the drug can be  
            prescribed off-label, while affording compassionate care and  
            good medicine to those most in need.  The California  
            Professional Firefighters, the Congress of California Seniors  
            and the Gray Panthers of Northern California also support this  
            bill, to protect patients access to those medications  
            necessary to the control of chronic and disabling conditions.

           4)OPPOSITION TO PRIOR VERSION  .  The California Association of  
            Health Plans (CAHP) and PacifiCare of California both opposed  
            an earlier version of this bill.  CAHP states that health  
            plans attempt, through formularies and prior approval  
            processes for certain drugs, to prevent inappropriate uses of  
            potentially dangerous medications.  CAHP states that not all  
            drugs are subject to prior authorization, but drugs that are  
            prescribed for off-label uses that may not be safe or  
            appropriate are subject to this process so that medical review  
            can be conducted.  Given the dangers, CAHP argues that  
            coverage for off-label drug prescriptions should not be  
            mandated unless the drug is necessary for a life-threatening  
            condition.

          The author and sponsor state that the most recent amendments,  
            which ensured that health plans could continue to use  
            formularies, copayments, technology assessment panels or  
            similar mechanisms to appropriately control the utilization of  
            off-label drug use, were intended to address opposition  
            concerns.  It is unclear whether these amendments have removed  
            the opposition to this bill.









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           REGISTERED SUPPORT / OPPOSITION  :

           Support  

          Genentech, Inc. (sponsor)
          California Professional Firefighters
          Congress of California Seniors
          Gray Panthers of Northern California
           
          Opposition  

          California Association of Health Plans (prior version)
          PacifiCare of California (prior version)

           Analysis Prepared by  :  Vince Marchand / HEALTH / (916) 319-2097