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A
To
start
the
fourth
interim
joint
committee
on
banking
and
insurance
of
the
2021
interim
session,
we
do
have
a
pretty
full
agenda
this
morning,
so
I
want
to
get
started
on
time,
and
hopefully
we
can
finish
up
here
within
about
an
hour
and
a
half
before
we
call
the
road.
We
have
any
members
who
need
to
recognize
any
guests
in
the
room
today.
A
President
in
the
room
as
well,
we
do
have
a
quorum
at
this
time.
A
Thank
you.
Thank
you.
We
do
have
a
quarrel,
so
I
will
entertain
a
motion
to
approve
the
october
5th
2021
minute.
So
I
get
a
motion
for
representative
lewis.
A
Second,
senator
alvarado,
all
those
in
favor,
aye
and
minutes
are
approved.
We
do
have
a
pretty
full
agenda
and
I
think
we'll
just
go
with
the
order,
we'll
go
in
order
as
it's
printed
on
the
agenda
today.
So
first,
if
we
have
commissioner
clark
and
the
folks
at
the
department
of
insurance,
are
you
online
with
us
yeah
good
morning?
Commissioner,
it's
good
to
have
you
with
us.
If
you
would
introduce
you
and
your
staff
and
the
topic
this
morning
will
be
an
update
on
mental
health
parity
laws.
K
Thank
you,
mr
chairman,
and
yes,
I'm
sharon
clark
the
commissioner
of
the
department
of
insurance
and
I
have
with
me
sean
horn,
who
is
an
executive
ambassador
with
the
commissioner's
office,
and
I
will
try
to
make
this
brief,
mr
chairman,
in
respect
of
your
time,
but
the
mental
health,
parity
and
addiction
equity
act
of
2008
generally
provides
the
financial
requirements
such
as
co-pays
coinsurance
and
treatment
limitations
imposed
on
mental
health
substance.
Abuse
disorders
cannot
be
more
restrictive
than
those
provided
for
medical
surgical.
K
In
december,
2020
congress
amended
the
act,
and
this
amendment
requires
the
insurance
companies
of
health
plans
to
perform
and
document
their
comparative
analysis
and
also
a
report
to
the
department
of
insurance.
This
self-compliance
tool
is
being
updated
in
the
near
future.
We're
also
working
on
these
tools
through
the
national
association
insurance
commissioners.
K
The
recently
enacted
house
bill
50
essentially
adopted
the
language
of
the
eqtl
requirements
of
the
federal
act.
The
bill
also
has
the
same
requirement
for
the
health
insurance
companies
to
submit
an
annual
report
so
going
forward
the
department
we'll
be
looking
at
ways
to
implement
the
requirements.
K
We
are
anticipating
to
promulgate
a
regulation,
but
again
we're
waiting
on
this
tool,
and
it
is,
it
is
a
very
complicated
tool.
It's
going
to
be
used
by
the
various
departments
and
trying
to
make
this
analysis
and
we're
working
diligently.
A
A
Commissioner,
you
must
have
done
a
very
good
job.
I
don't
see
any
questions
at
this
time.
Thanks,
sir,
we
appreciate
you
being
with
us.
Will
you
all
be
monitoring
the
rest
of
the
committee
and
available?
Should
questions
come
up
on
other
topics?
A
Moving
along
to
our
next
topic,
it
will
be
insurance
coverage
for
the
treatment
of
eating
disorders.
We
have
melissa
cahill
here
she
is
the
chair
of
the
kentucky
eating
disorder,
council
I'll.
Let
her
come
to
the
table,
introduce
herself
and
the
rest
of
the
group
who
will
be
presenting
with
you
this
morning.
L
L
We
appreciate
your
time
today
in
allowing
us
to
do
this
testimony.
Our
topic
is
mental
health
parity,
which
it's
very
appropriate
being
that
sharon
clark
just
spoke
and
eating
disorder
treatment
in
our
state.
L
All
right
just
to
give
everybody
a
kind
of
a
basis
for
where
eating
disor
orders
are
in
the
state
of
kentucky.
They
are
currently
an
epidemic
in
the
state.
There
are
approximately
900
000
individuals
diagnosed
with
an
eating
disorder
and
of
those
29
000
are
children
in
our
state
right
now.
There
are
zero,
acute
care
programs,
zero,
residential
and
zero
partial
hospitalization
programs.
So
anyone
diagnosed
with
this
illness
that
needs
a
higher
level
of
care
than
outpatient.
L
They
are
required
to
go
out
of
state.
That
is
their
only
option
and
individuals
that
have
medicaid
in
our
state
really
have
few
to
know
options,
because
not
many
out-of-state
providers
will
work
with
kentucky
medicaid
eating
disorders
as
an
illness
are
a.
They
have
a
high
mortality
rate.
I
don't
think
a
lot
of
people
realize
that,
in
fact,
anorexia
nervosa
has
the
second
highest
mortality
rate
of
any
psychiatric
illness.
Second,
only
to
that
of
opioid
use
disorder.
They
are
really
debilitating.
L
So
the
reason
we
are
here
is
that
the
kentucky
eating
disorder
council
was
created
to
address
the
serious
nature
of
these
illnesses
and
to
really
work
on
improving
what
kentucky
residents
have
to
face
when
they
are
diagnosed
with
this
illness.
We
are
charged
with
prevention,
early
detection,
education
and
research,
but
I
think
the
most
important
goal
of
the
council
is
to
provide
more
access
to
quality
care
for
all
kentuckians.
L
Oh,
you
can
go
back,
one
slide,
sorry.
So
what
are
some
of
the
barriers
that
kentuckians
are
facing
when
diagnosed
with
an
eating
disorder?
First
and
foremost,
there's
a
lack
of
providers
that
participate
with
insurance.
There's
a
limited
number
limited
number
of
professionals
that
actually
treat
eating
disorders.
The
demand
is
high
for
the
services
and
the
supply
of
qualified
individuals
is
very
low.
L
The
review
criteria
used
by
insurance
companies
really
doesn't
accurately
reflect
what
goes
into
treating
an
eating
disorder.
So
often
people
are
discharged
before
they're,
even
medically,
stable
or
ready
to
move
to
a
lower
level
of
care.
People
are
forced
to
go
out
of
state
for
care,
and
that
doesn't
you
know,
even
if
it's
in
network
it
doesn't
account
for
travel
costs,
lodging
medications
labs
all
the
additional
fees
that
go
with
treatment
and
once
they
are
discharged,
they
come
back
to
the
state
of
kentucky
and
find
themselves
in
the
same
position.
L
So
why
don't
providers
participate
in
network?
The
basic
answer
is
reimbursement
rates
for
mental
health
providers
are
so
low.
They
are
unable
to
be
in
network
with
many
of
the
insurers.
So
when
someone
goes
to
find
care
they're
looking
for
an
in-network
provider,
they
can't
find
one
they're
forced
to
go
out
of
network
which
often
delays
treatment
limits,
the
amount
of
treatment
they
can
get
or
afford,
and
ultimately
some
of
those
individuals
just
don't
seek
care.
L
L
One
of
the
statistics
that
really
rang
true
was
that
out
of
network
utilization
rates
for
mental
health
compared
to
that
of
primary
care
on
average
five
times
higher
people
have
to
go
out
of
network
for
mental
health
care.
They
also
analyzed
reimbursement
rates
compared
to
primary
care
relative
to
medicare
and
on
average
mental
health
providers.
In
the
years,
2013
14
and
15
received
29.5
less
than
their
primary
care
counterparts.
That's
a
significant
number,
so
limited
number
of
providers
low
reimbursement
rates.
L
L
It's
geographically
challenging
for
a
lot
of
kentucky
residents.
We
need
to
improve
telehealth
access
for
those
areas
that
can't
geographically
access
care.
Very
important
and
managed
care
often
does
interfere
with
the
course
of
treatment
with
premature
discharges
sending
people
home
with
no
step
down
programs
available.
L
So
that
is
where
we
are
in
summary,
and
I
wanted
to
give
justin
wallen
the
opportunity
to
discuss
this
situation
from
a
provider's
side.
M
Good
morning
she
mentioned,
my
name
is
justin
wallen,
I'm
the
business
manager
for
the
louisville
center
for
eating
disorders.
M
For
the
louisville
center
for
eating
disorders
in
louisville
kentucky
we're
the
only
practice
in
the
state
that's
actually
offering
a
higher
level
of
eating
disorder
care
that's
covered
by
any
insurance
at
all.
Treatment
of
eating
disorders
requires
some
very
specialized
training,
a
lot
of
extensive
education
and
evidence-based
treatments,
as
well
as
continuing
education
courses.
M
Our
providers
at
the
louisville
center
are
masters
and
doctoral
level.
Therapists
with
you
know,
with
this
extensive
training
and
they
require
and
deserve
adequate
compensation
to
actually
remain
and
continue
performing
these
services
in
the
state
a
little
history
of
our
relationship
with
insurance.
We
started
our
intensive
outpatient
program
in
october
of
2017.
M
At
that
time
we
were
out
of
pocket
self-pay.
Only.
We
realized
very
quickly
that
you
know
we
weren't
going
to
be
able
to
help
a
sufficient
number
of
people.
You
know
having
to
charge
out
of
pockets.
So
in
january
of
2019
we
were
first
able
to
get
in
network
with
a
couple
of
insurance
companies.
You
know
still.
The
rates
were
insufficient
to
support
a
program
long
term.
Since
that
time
costs
have
increased
so
and
early
this
year
we
began
renegotiating
those
contracts.
M
You
know
it's
11
months
later
and
we
still
haven't
made
any
progress.
At
that
same
time,
we
also
started
looking
into
adding
a
partial
hospitalization
program,
so
that's
a
six
hour,
a
day
program
versus
the
three
hour
iop
program.
Again
those
negotiations
haven't
gotten
very
far
in
the
11
months,
since
we
started
them
and
and
that
six
hours
a
day
as
well
as
all
the
additional
costs
involved
with
that,
there's
no
way
that
that
level
of
care
is
going
to
be
accessible
to
anyone
in
kentucky
out
of
pocket.
M
A
little
bit
about
our
experience
so
far
being
in
network
for
eating
disorder,
higher
level
of
care
from
a
business
perspective,
it's
just
been
very
costly
and
frustrating
requires
full-time
staff.
Members
to
to
deal
with
them
sit
on
the
phone
with
them
all
day.
You
know
every
day
we
have
outside
vendors,
we
have
to
supply
our
billing
to
them,
and
then
it
just
involves
significant
therapist
involvement
that
takes
away
from
a
lot
of
patient
care.
M
We
also
run
into
issues
with
last-minute
denials
where
essentially
the
insurance
company
says
they
can't
pay
for
you
know
another
day,
so
ethically
we
can't
stop
seeing
the
patients,
so
we
end
up
bearing
those
costs
ourselves.
Just
from
a
patient's
perspective.
I
think
it's
just
a
lot
of
uncertainty
involved.
M
There's,
always
the
risk
of
being
cut
off
of
treatment.
We
often
find
that
a
lot
of
these
decisions
to
end
treatment
are
arbitrary
and
made
by
people
without
any
experience
with
eating
disorders
at
all
and
then
just
from
a
state
perspective.
I
think
this
displays
some
serious
issues
with
the
power
that
insurance
companies
have
over
providers
that
are
trying
to
offer
this
much-needed
care.
L
All
right,
thank
you.
Justin
dr
kraussie
hi.
O
My
name
is
dr
andrea
krause
and
I
am
a
board
certified
pediatrician.
I
practice
hospital-based
care
through
norton
children's
hospital.
I've
been
there
for
the
past
15
years
for
the
past
12
of
those
years.
I
have
actually
been
the
the
physician
that
helps
to
stabilize
our
sick
eating
disorder,
patients
that
get
admitted
to
the
hospital,
and
so
that's
a
unique
position
to
be
in.
I
would
say
that
you
know
with
what
I
do.
O
That
is
definitely
a
catch-all,
and
so
I
see
the
failures
that
we
have
here
in
the
commonwealth
of
kentucky
due
to
lack
of
access
and
there's
two
things
that
play
into
that
one.
On
one
side
of
things,
we
do
have
some
poor
recognition
out
in
the
community
by
providers,
whether
it's
primary
care
providers
or
whether
it's
you
know,
mental
health
therapists
that
don't
have
experience
with
eating
disorders,
so
there
sometimes
can
be
a
slow
recognition
of
what
illness
is
actually
happening
to
this
child
and
then
on
the
other
side
of
things.
O
There's
also
that
poor
access
to
appropriate
care,
and
so
as
these
delays
occur
for
these
patients.
Basically,
you
know
further
delays
in
treatment.
The
child
is
simply
going
to
have
a
downward
spiral
and
that
can
be
with
worsening
kind
of
behaviors
and
weight
loss
that
goes
with
it,
and
so,
by
the
time
they
see
me
they
are
near
death,
and
so
my
job
is
to
medically
stabilize
them
next
slide.
O
Please
so
2021
has
also
been
quite
unique
in
that
we've
had
an
almost
twofold
increase
in
the
number
of
medically
unstable
eating
disorder,
patients
that
have
been
admitted
to
norton
children's
hospital,
and
that
is
on
top
of
a
year
to
year
increase
of
about
20
percent
per
year
for
the
past
10
years
is
the
pattern
that
I
have
been
seeing.
O
I
would
say
that
these
kids
are
sicker
than
ever,
and
I
believe
this
is
due
to
the
lack
of
access
and
care
in
the
commonwealth.
Our
peer
mix
breakdown
is
about
stable,
typically
60
of
my
patients
that
I
see
with
eating
disorders
are
privately
insured,
yet
40
are
on
kentucky
medicaid.
O
So
the
other
additionally,
you
know
insurance
payers.
A
lot
of
times
do
not
seem
to
be
aware
of
our
published
guidelines
by
the
american
psychiatric
association
as
well,
the
as
the
american
academy
of
pediatrics
regarding
our
appropriate
levels
of
care
and
what
fulfills
the
appropriate
level
of
care
for
eating
disorder
treatment.
I
actually
once
had
to
have
a
peer-to-peer
review
explaining
to
an
insurance
reviewer
that,
in
fact,
failure
to
thrive,
get
guidelines
which
would
appropriately
be
for
infants,
is
not
an
appropriate
guideline
to
use
for
a
teen
eating
disorder
patient.
O
O
O
So
basically,
that
is
to
say
that
any
medicaid
patient
that
comes
to
me
medically
unstable,
is
going
to
stay
there
for
weeks,
if
not
months,
in
the
hospital
due
to
lack
of
placement
options
and,
of
course
that
is
detrimental
to
treatment.
I
can
weight,
restore
a
child,
but
ultimately
to
fix
the
psychology
behind
the
illness
is
not
something
I
can
do
at
the
children's
hospital.
P
I
had
not
planned
to
do
that
during
these
last
four
years
she
has
had
two
acute
care:
hospitalizations,
two
partial
hospitalizations,
four
residential
stays
and
continuous
outpatient
therapy
and
nutritional
care
and,
as
you've
heard
kentucky
does
not
have
partial
hospitalization
programs.
Kentucky
does
not
have
residential
care
programs
and
very
limited
outpatient
therapy.
P
P
P
The
step
down
from
acute
care
is
partial.
Hospitalization
and
again,
my
granddaughters
had
two
out
of
state
stays
in
partial
hospitalization
programs.
One
stay
was
covered
by
insurance
and
one
was
not
again.
The
struggle
is
finding
a
provider,
that's
willing
to
negotiate
an
agreement
to
pay
for
the
services.
P
So
that
requires
you
to
also
have
either
an
apartment
or
an
extended
stay
somewhere,
so
that
you
can
be
there
at
night
to
provide
the
services
that
are
needed
when
you
get
past
a
partial
hospitalization
program
and
the
residential
program,
you
step
down
to
the
intensive
outpatient
care.
My
granddaughter
has
gone
through.
Two
one
was
covered
by
insurance
in
state.
The
other
was
not.
P
P
So
not
only
do
you
have
the
cost
of
the
treatment
if
the
provider
is
unwilling
to
negotiate
a
single
case
agreement,
but
you
also
have
travel
costs
and
living
costs
in
your
packet
of
information.
I
believe
you
have
an
article
from
the
wall
street
journal
and
the
title
of
that
article
is
called
why
it's
so
hard
to
find
a
therapist
who
takes
insurance.
P
L
L
Based
upon
this
testimony,
it
is
evident
that
kentucky
must
change
some
of
its
mental
health
insurance
laws.
First
and
foremost,
we
need
to
improve
reimbursement
rates
for
existing
providers
so
that
the
the
providers
that
we
already
have
in
our
state
can
provide
care
to
those
that
so
desperately
need
it.
We
also
need
to
create
some
incentives
for
practitioners
to
want
to
practice
in
kentucky.
L
Improving
the
reimbursement
rates
will
help
tax
incentives,
educational
opportunities.
We
need
to
attract
qualified
individuals
to
kentucky.
We
also
need
to
change
the
review
criteria
for
eating
disorder
care.
It
needs
to
accurately
reflect
what
care
for
an
eating
disorder
requires
and
we
need
to
ease
some
of
the
state
licensure
laws
for
cross-state
telehealth
services,
so
those
in
areas
that
are
unable
to
access
care
have
that
access,
and
I
know,
we've
probably
gone
over
our
time.
L
So
we
are
asking
legislators,
this
committee,
the
department
of
insurance,
to
really
take
a
very
serious
look
at
first
off
the
reimbursement
rates
to
see
if
we
can
move
the
ball
forward
and
actually
get
the
care
that
the
residents
of
our
state
deserve
for
this
disorder.
And
we
thank
you
so
much
for
your
time
and
we're
open
for
any
questions.
You
may
have.
A
Q
N
I
have
a
daughter
who's
a
psychologist
today
because
of
an
eating
disorder
when
she
was
13
year
old
and
the
reason
the
eating
disorder
come
along
is
because,
even
as
beautiful
as
she
was,
she
was
told
she
was
fat,
and
so
we
didn't
realize
what
was
going
on
and
what,
anyway,
as
people
as
we
learned
more
about
this,
my
wife
knows
all
about
it.
I
I
know
a
little
enough
to
be
dangerous,
probably,
but
it's
more
of
a
a
mental
aspect,
and
then
it
turns
into
a
physical
aspect.
N
Now
she
didn't
go
on
to
the
point
of
needing
hospitalization
and
all
that
stuff
and
thank
god
she
didn't
the
question.
I
have
and
there's
two
of
them
since
instagram.
N
Doctor,
do
you
see
more
of
this
because
of
little
girls
getting
on
there
and
beating
on
other
little
girls?
I
know
us
boys,
we
didn't
care,
but
it's
always
seems
like,
and
I'm
sure
you
probably
got
some
some
gentleman,
some
young
man,
but
it's
always
in
the
young.
Ladies.
They
all
want
to
look
like
center
rocky
adams,
but
they
have
to
look
like
senator.
J
N
So
anyway,
the
point
is
I
I
guess
my
basic
question
is:
is
it
more
prevalent
today
because
of
media
or
because
of
the
things
we
have.
O
I
yes,
I
think
that
has
been
documented
in
the
literature
as
well,
that
those
outside
pressures
are
there
and
really
kind
of
unavoidable
to
to
the
growing
adolescent
brain.
Unfortunately,
so
they
used
to
show
old
studies
saying
that
just
fashion
magazines
would
affect
your
self-esteem.
But
now
it's
so
much
worse.
N
Problems
yeah,
you
know
problems
is,
and
I
know
it
turns
into
a
physical
aspect
of
it.
That
was
my
biggest
thing.
What
are
you
having
problems
collecting?
Because
it's
a
mental
aspect?
I
know
dr
alvarado,
where
you
at
doc
don't
stab
me
again,
ain't
you.
No
all.
A
N
Anyway,
dr
alvarado
deals
with
a
lot
of
the
physical
part
of
it
and,
and
the
physical
part
of
it
is
probably
covered
the
the
the
the
things
it
brings
on
with
the
stomach
ailments
or
the
things
that
goes
with
the
the
anorexic
or
all
that
I
don't
know.
If
is
that
a
problem
getting
paid
trying
to
draw
the
line
of
what's
physical
and
what's
mental
or.
L
Well,
I
think
it's
it's
the
the
problem
with
eating
disorders.
Is
it's
very
complex?
It's
a
little
bit
of
both.
You
need
to
take
care
of
the
medical
side
of
it
and
until
the
medical
side
is
kind
of
brought
to
where
the
patient
needs
to
be
where
they
are
healthy,
then
the
work
begins
on
the
actual
changing
of
the
thought
patterns
and
the
psychological
side
of
it,
and
they
kind
of
you
know,
go
hand
in
hand
just
because
someone
is
weight
restored
with
an
eating
disorder
doesn't
mean
they're
cured.
L
L
N
And
that's
brought
on
by
mental
aspect
too,
so
why
can't
this
be
a
and
I'm
an
insurance
person,
or
was
I
retired?
Thank
goodness,
but
I
I
don't
see
that
these
young,
ladies
and
they
do
have
a
major
issue.
N
R
P
If
I
may,
you
know,
I
think
the
disorder
seems
to
be
more
prevalent
in
females
and
in
young
girls.
I
don't
want
to
forget
that
there
are
young
males
and
males
who
suffer
from
this
disorder
as
well.
In
fact,
the
first
residential
program,
where
my
granddaughter
was
there
were
two
young
young
gentlemen
there,
so
it
it
doesn't
discriminate.
A
S
L
Yes,
currently
in
the
state
of
kentucky,
there
are
900
000
individuals
diagnosed
with
an
eating
disorder
and
of
those
little
over
29
000
are
children
or
adolescents
wow.
Thank
you
very.
S
C
Senator
alvarado,
thank
you,
mr
chairman,
and
thank
you
all
a
couple
of
things.
I
think
some
of
the
comments
you've
made,
I'm
a
pediatrician
also
and
I've
had
patients
present
to
me
with
eating
disorders.
Parents
concerned
people
that
need
to
be
hospitalized,
and
I
think
sometimes
it's
important
for
us
to
talk
about
the
graphic
nature
of
what
this
disorder
is.
We
think
about
it.
I
think
people
often
think
well,
it's
just
you
know
you
need
to
eat.
C
If
you
just
eat,
you'll
get
better
you'll,
be
fine
and
that's
as
simple
as
it
gets,
and
for
most
of
us
that's
the
mentality.
If
we
don't
have
the
disorder
itself,
but
these
are
individuals
who,
if
they
have
any
aspects
of
bulimia
as
they
throw
up
the
acid,
the
corrosion
of
teeth,
the
damage
their
esophagus.
C
You
know
the
obviously
the
weight
loss,
the
electrolyte
abnormalities
that
occur
end
organ
damage
that
can
occur
from
those
things:
people's
potassiums
get
very,
very
low.
All
kinds
of
electrolytes
can
be
really
messed
up,
and
so
often
for
me,
as
a
pediatrician
you'd
admit
them,
you
get
them
hydrated.
You
correct
all
those
deficiencies
and
you
were
left
a
little
bit
with
what
do
I
do
now
and
not
being
a
psychiatrist
or
an
expert
in
this
field.
C
C
It
was
really
a
shortage
of
providers
and
I
want
to
remind
all
of
our
members
that
there
was
a
task
force
that
was
set
up
to
address
the
shortage
of
providers
done
in
2013,
with
several
recommendations
that
are
there
that
we've
proposed
those
recommendations,
and
I
I
file
some
of
those
every
year
I'll
continue
to
file
those
every
year
and
in
hopes.
Some
of
my
colleagues
will
start
to
take
this
matter
seriously
because
the
longer
we
wait,
the
harder
it
is
to
attract
providers.
We
can't
pop
them
out
of
a
gumball
machine.
C
It
takes
for
a
physician,
11,
12
14
15
years
to
get
a
physician
in
that
role
and
if
we
start
the
process
now
we'll
be
seeing
those
effects
in
10
or
15
years
down
the
line,
I
can
go
on
for
a
long
time.
I
won't
bore
everybody
to
death,
so
I
appreciate
some
of
the
comments
you've
made
about
the
importance
of
that.
Can
you
describe
some
of
the
specialists?
You
need
obviously
can
a
board
certified
pediatrician
be
the
aspect.
C
We
know
that
child
psychiatrists
are
often
some
as
what
we
need
and
we've
only
got
59
child
psychiatrists
in
the
state
of
kentucky.
Only
half
of
those
take
any
kind
of
insurance.
The
rest
are
self-pay
because
they're
up
to
here
with
dealing
with
insurance
companies
and
there's
they're
full
they're,
absolutely
full
with
people
paying
self-pay.
Not
everyone
can
afford
that.
Maybe
you
can
talk
about
the
specialists
that
are
required
in
all
aspects
and
what
we
need
to
help
attract
those.
O
Right
so,
ideally-
and
thankfully
I
do
have
a
team
that
works
with
me
at
norton
children's,
but
the
child
psychiatrists
are
key
child
and
adolescent
psychologists
as
well
registered
dietitians
that
actually
have
training
in
eating
disorders.
Not
just
any
registered
dietitian
will
have
knowledge
of
how
to
counsel
through
this
illness,
and
it
really
is
multidisciplinary.
We
have
other
types
of
therapists
like
expressive
and
art
therapy.
Child
life
therapy
is
what
I
have
access
to
with
my
team,
but
it
it
takes
more
than
one
person.
That's
for
sure.
C
Also
with
regards
to
telehealth
mr
trump,
if
I
could
briefly,
we
probably
have,
I
would
argue,
the
top
telehealth
bill
in
the
country
right
now
and
as
long
as
a
provider
is
licensed
in
the
state
of
kentucky,
they
can
see
patients
from
anywhere
in
the
world.
Not
all
states
have
that
many
of
them
say
you've
got
to
be
within
our
state
borders.
As
long
as
they're
licensed
in
the
state
and
they're
going
to
get
a
kentucky
license
in
whatever
field
they
can
provide
those
services
from
anywhere.
C
We've
worked
very
hard
and
representative
fraser
and
myself
have
run
those
bills
in
the
past
that
many
states
are
starting
to
try
to
copy.
What
we're
doing
here
so
know
that
the
telehealth
laws
are
pretty
expansive
if
you've
got
providers
in
other
states
who
want
to
see
our
patients
here
as
long
as
they're
licensed,
they
can
provide
that
care
from
anywhere.
C
So
we
try
to
expand
our
borders
as
much
as
we
can
to
let
people
be
treated
by
the
specials
that
we
need,
but
tort
reform
is
a
big
thing,
I'll
be
filing
that
again,
I
know
members
of
this
committee,
most
of
them,
are
in
agreement
on
that
topic.
We've
got
to
start
looking
at
that,
as
well
as
a
big
issue
in
the
state
and
again
some
of
those
recommendations.
I
would
urge
everybody
to
remember
to
look
at
that
in
the
future.
Thank
you,
mr
chairman.
B
Thank
you,
mr
chairman,
and
thank
you
all
for
being
here
today,
and
it
really
is
an
honor
to
work
with
you
all
on
this,
and
I
I
agree
with
representative
westrom.
We
have
nine
hundred
000
people
in
this
state
who
are
affected
by
this
disorder
and
disease.
I
All
right
morning,
mr
chairman,
well
I
mean
certainly
that's
something
we're
going
to
look
at
under
the
mental
health
parity
act.
That's
been
passed
house
bill,
50
and
see
how
that
is
going
to
presently
affect
going
forward,
how
to
enforce
that
parity
among
the
different
providers
of
the
medical
and
surgical
and
the
mental
health
aspect
of
it.
K
And
I
would
add
that
you
know
the
department
is
certainly
willing
to
facilitate
a
yes,
a
communication
session
with
the
health,
insurers
and
the
members
of
the
council
to
try
to
update
them,
and
you
know
to
explain
the
issues
that
they're
having
and
I
think
it
was
dr
krauss
that
was
saying
that
there
was
you
know
they
were
unaware
of
some
of
the.
You
know
the
provisions
of
what
is
needed,
but
you
know
we
would
certainly
be
willing
to
do
that.
K
B
Thank
you
for
that
response,
and
I
look
forward.
It's
not
just
a
parity
issue,
but
it's
an
equity
issue
and
it's
an
issue
that
if
other
states
have
figured
out
how
to
achieve
parity
and
how
to
achieve
equity,
that
I'm
sure
that
kentucky
can
figure
out
how
to
do
the
same
thing.
So
I
do
look
forward
to
this
council,
interacting
with
the
department
of
insurance.
B
I
think
it's
important
that
we
have
those
conversations,
and
I
know
I
stand
ready
along
with
it
seems,
like
many
members
of
this
committee,
to
continue
trying
to
help
in
that
effort
to
get
that
parity
to
get
those
reimbursement
rights,
because,
quite
honestly,
our
citizens
deserve
it.
So
thank
you
very
much
for
all
the
work
that
you
do.
I
Thank
you.
Thank
you
to
the
presenters
one
quick
thing
I
had
the
great
honor
several
years
ago
to
teach
for
an
extended
period
of
time,
mindfulness
of
meditation
to
the
eating
recovery
center
in
cincinnati
and
had
some
first-hand
experience
through
this
and
the
great
work
that
you
all
do.
That
facility
is
the
closest
one
to
people
in
my
district,
but
it
is
out
of
state
and
out
of
network
for
many,
and
so
I've
also
heard
some
of
those
same
issues.
I
I'd
also
like
to
just
take
this
opportunity
to
remind
us
all
that
words
really
matter
and
that
when
we're
here
and
we
have
the
microphone,
I
just
ask
all
of
us
to
be
as
thoughtful
and
compassionate
as
possible
when
I
was
there,
I
noticed
that
it
was
maybe
predominantly
female,
but
not
entirely
by
any
stretch
of
the
imagination,
and
this
isn't
a
problem
of
girls
being
mean
to
girls.
I
I
My
question
is
this:
given
the
problems
we
face
and
the
solutions
that
you
presented
to
us,
some
of
which
may
take
us
some
time
to
solve,
could
you
talk
about
any
ideas
you
have
for
early
intervention
ideas
that
might
be
able
to
help
us
in
the
shorter
term
and
specifically
where
it
comes
to
really
trying
to
get
young
people
to
go
into
the
psychiatric
fields
in
the
mental
health
field,
so
we
can
start
to
grow
a
crop
of
new
providers
for
our
state.
Thank
you.
L
L
First
of
all,
is
already
utilizing
the
already
established
community
mental
health
centers
and
leveraging
the
care
in
those
communities
that
already
exist
by
providing
educational
opportunities
for
those
people
there.
So
things
are
detected
earlier,
introducing
prevention
programs
we've
already
done
well,
I
wish
kate
wagner
were
here
our
administrator.
L
As
far
as
some
of
those
things
we're
doing
an
advocacy
day
in
march
that
we
will
have
lots
of
information
we'll
be
in
the
state
capitol
rotunda
for
that
day
and
every
week
we're
working
towards
providing
more
information
and
using
systems
already
in
place
through
the
prevention
branch.
L
You
have
to
keep
in
mind
too
that
everyone
on
this
council
is
doing
this
as
a
volunteer
because
they're
passionate
and
they
care
about
this
issue,
and
I'm
you
know
I
wish
I
could
work
full-time
on
it.
Unfortunately,
I
can't
so
we're
moving
forward
and
I
think
we've
accomplished
a
lot
as
far
as
attracting
more
young
people
into
the
mental
health
fields.
I
I
don't
know
if
you
have
any
thoughts
on
that.
O
I
think
that,
just
you
know
I'm
associated
with
the
residency
program,
the
pediatric
residency
program
through
university
of
louisville,
and
so
definitely
our
outreach.
There
is
for
ongoing
education
and
as
well
the
the
psych
team
that
I
work
with
also
have
interns
and
postdoc
fellows
that
come
through
their
program
as
well.
It's
just,
I
feel
I
do
feel
like
a
lot
of
those
people
end
up
not
staying
and
kind
of
going
away
to
different
states.
So
thank
you.
A
Thank
you
and
thank
you
all
for
being
here
this
morning
and
for
the
time
you
put
into
your
presentation
and
testimony.
I
think
it
was
a
really
good
educational
experience
for
our
committee
members
and
those
are
the
kind
of
topics
that
we
like
to
hear
about
in
the
interim.
So
thank
you
all
for
being
here.
A
All
right,
our
final
topic
this
morning
will
be
regulation
of
air
ambulance.
G
They're
sold
at
state
fairs
at
shopping
malls
at
kids,
ball
games
and
also
by
mailers.
But
what
are
but
what
they
are
and
what
benefit
do
they
provide
to
policyholders
on
its
face?
An
air
ambulance
membership
subscription
claims
to
protect
against
out-of-pocket
costs
in
the
rare
event
of
transportation
by
an
air
ambulance,
but
who,
if
anyone
actually
benefits
from
a
membership
policy
in
the
event
of
transportation?
G
G
What
I
propose
to
provide
your
constituents
and
my
constituents
is
the
consumer
protections
and
rate
transparencies-
that's
provided
to
them
on
every
other
insurance
product
out
there
in
the
marketplace
further,
when
the
federal
no
surprise
act
goes
into
effect
on
january
1st,
thereby
preventing
patients
from
receiving
balancing
bills.
What
benefit
will
these
policies
then
provide?
G
And
that
is
the
question
I
want
to
answer
for
my
constituents,
especially
those
on
fixed
incomes
who
today,
who
are
buying
these
memberships
out
of
fear,
it's
time
that
we
take
a
hard
look
at
these
policies
and
provide
consumers
of
kentucky
with
needed
protections
from
predatory
policies
and
marketing
tactics,
for
example,
in
kentucky
alone,
currently,
gmr
says
that
there
are
two
hundred
and
eighty
seven
thousand
memberships
at
an
annual
membership
cost
of
eighty
five
dollars.
If
you
do
the
math,
that's
twenty
four
point:
four
million
one
tenth
of
one
percent
will
actually
utilize
this
service.
G
R
Thank
you,
chairman
roland
chairman
carpenter,
members
of
the
committee.
As
I
stated,
my
name
is
chris
brady,
I'm
the
general
counsel
at
air
methods.
Corporation
air
methods,
corporation
operates,
seven
aeromedical
transport
bases
in
the
state
of
kentucky.
You
know
we
have
over
a
hundred
employees
working
on
the
front
lines
of
health
care
to
deliver
these
life-saving
services
to
your
constituents.
R
I'm
glad
to
be
here
today
to
discuss
a
very
important
topic
for
consumers
in
kentucky
and
the
regulation
of
air
ambulance
memberships.
I
understand
there
was
legislation
introduced
last
year
on
this
issue.
However,
this
is
the
committee's
first
hearing
and
I'd
like
to
provide
some
updates,
given
the
evolution
of
the
implementation
of
the
no
surprises
act
and
continued
regulation
of
these
products
in
other
states
to
be
clear
at
the
outset.
R
I
am
not
here
today
to
argue
for
the
prohibition
of
ariem
loans-
memberships,
as
unfortunately,
you
may
have
been
told.
Rather,
air
methods
supports
state
regulation
of
these
products
by
the
department
of
insurance
to
ensure
that
consumers
are
protected
in
the
same
manner
as
policyholders
of
other
forms
of
supplemental
insurance
products
in
kentucky
and
not
deceived
into
purchasing
coverage.
They
simply
do
not
need
the
pending.
Enactment
of
the
federal
no
surprises
act
makes
this
issue
even
more
important
than
ever
before.
R
R
Premiums
that
would
now
be
inflated
and
incorrect
from
a
pooled
risk
perspective
should
result
in
a
substantial
savings
for
policyholders
facing
this
looming
shift
in
the
air
ambulance.
Industry,
purveyors
of
air
ambulance.
Memberships
have
shifted
from
describing
memberships
as
prepaid
air
medical
services
to
a
prepayment
of
deductibles
or
copays.
R
This
narrative
shift
glosses
over
two
significant
flaws
in
these
products
that
continue
to
lead
to
consumer
harm.
First,
many
consumers
are
sold
memberships
without
appropriate
disclosure
and
with
fear-driven
pressure
tactics
even
more.
Concerning
these
memberships
may
auto
renew
leaving
consumers
locked
into
yearly
premiums,
even
when
they
reach
medicare
coverage
age,
profiting
off
consumer
fears
of
facing
a
lifetime
of
economic
insolvency.
R
R
R
Rural
medicare
beneficiaries
are
particularly
vulnerable
to
the
sales
pitch
of
air
ambulance
memberships
as
they
live
in
remote
areas
where
the
majority
of
air
ambulance
medicare
transports
originate.
Yet
they
have
the
fewest
financial
resources
available
with
over
42
percent
of
rural
medigap
policyholders,
relying
on
annual
incomes
below
thirty
thousand
dollars.
According
to
a
hips
2019
analysis,
rural
seniors
should
not
be
made
to
think
that
they
must
allocate
their
hard-earned
dollars
to
buy
air
ambulance
insurance
coverage.
R
Nowhere
on
any
air
ambulance
membership
websites
are
consumers
alerted
to
the
potential
for
duplicative
coverage
between
their
existing
medigap
coverage
plans
and
air
ambulance
memberships.
Instead,
medicare
consumers
are
offered
a
discount
to
encourage
membership
and
provided
conclusive
assurances
that
air
ambulance
memberships
could
be
useful
if
supplemental
insurances
did
not
cover
co-pays
or
deductibles.
R
R
R
Given
the
acuity
of
our
patients,
these
insurance
claims
are
often
expensive
and
a
single
claim
may
fulfill
the
patient's
maximum
out-of-pocket
responsibility
under
their
insurance
policy.
The
benefit
of
a
membership
in
these
situations
simply
comes
down
to
which
health
care
provider
submits
their
bills.
First
selling
a
membership
for
a
service
that
a
consumer
has
less
than
one-tenth
of
one
percent
of
activating
no
less
needing
under
the
guise
of
providing
peace
of
mind,
is
dubious.
At
best,
membership
products
are
marketed
and
sold
as
insurance
products.
R
Air
methods
own
records
indicate
that
over
200
patients
have
delayed
care
to
wait
for
a
covered
air
ambulance
membership,
rather
than
utilizing
the
closest
most
appropriate
provider
selected
by
a
third
party,
first
responder
or
physician
further.
Just
this
year,
a
medicare
patient
in
another
state
refused
transport
with
air
methods
to
wait
for
another
provider
due
to
a
membership.
The
membership
provider
was
not
available
for
several
hours,
but
the
patient
still
refused
a
non-covered
transport
and
eventually
passed
away
in
the
hospital.
R
R
The
passage
of
the
no
surprises
act
only
reinforces
the
need
for
oversight
of
ariemon's
memberships
to
protect
policyholders
from
predatory
products
designed
to
solicit
premiums
while
effectively
providing
no
value
to
them
or
their
families.
In
return,
companies
that
sell
memberships
believe
these
products
operate
above
state
law.
However,
states
can
and
do
regulate
air
ambulance
membership
subscriptions
good
examples
of
this
are
florida
and
new
york
and
the
national
council
of
insurance
legislators
continues
to
study
model
legislation
that
would
serve
as
a
blueprint
for
states
wanting
to
rein
in
predatory
behavior.
A
Thank
you.
I
think
what
we'll
do
is
allow
global
medical
response
to
come
to
the
table
for
their
response
and
then
we'll
do
questions
we'll
do
questions
after
that,
so
we'll
we'll
get
them
all.
At
the
same
time,
elizabeth
ward,
regional,
director
of
kentucky
operations
for
global
medical
response
and
jason
mundy.
T
Hello,
I'm
elizabeth
ward,
I'm
a
1993
graduate
of
eastern
kentucky
university,
I'm
a
resident
of
kentucky,
I'm
a
kentucky
licensed
registered
nurse
and
emergency
medical
technician.
I'm
here
today
representing
area
back
life
team.
I
have
worked
for
area
back
life
team
for
more
than
20
years,
and
I'd
like
to
publicly
thank
many
of
the
members
of
our
audience.
Today
are
here
also
from
area
back
life
team.
More
than
a
dozen
people
in
the
audience
today
are
with
my
organization.
I
have
the
honor
to
sit
here
and
represent
them
in
kentucky.
T
T
T
I
hope
I
never
need
you,
but
I'm
glad
you're.
Here
our
programs
help
give
them
a
peace
of
mind
in
their
community
and
as
a
nurse
that
is
important
to
me.
Membership
does
matter,
and
I
don't
want
to
take
up
too
much
time,
but
because
membership
matters
I
did
invite.
We
have
here
with
us
today.
Our
subject
matter
expert
I'd
like
to
introduce
to
you
our
national
director
of
membership
field
sales,
mr
jason
monday.
E
Good
afternoon
and
thank
you
for
the
opportunity
to
testify
today,
as
elizabeth
said,
my
name
is
jason
money.
I'm
the
national
director
of
membership
field
sales
for
the
american
air
medicare
network,
which
is
a
global
medical
response
solution.
I
am
here
to
testify
against
proposed
changes
to
21rsbr
1296,
classifying
area
with
providers
that
offer
membership
to
be
considered
as
insurers
and
also
ambulance
provider
membership
programs
to
be
considered
as
limited
health
service
benefit
plans.
E
Global
medical
response
has
numerous
air
ambulance
bases
providing
life-saving
services
within
the
state.
We
have
provided
air
ambulance
memberships
in
kentucky
for
over
21
years,
currently
more
than
over
200
000
kentuckians,
most
of
whom
limited
rural
communities
nearby.
Our
bases
have
made
a
consumer
choice
to
be
a
part
of
the
air
medicare
network
membership
program.
They
do
not
want
you
to
take
away
their
choice
to
have
a
membership.
E
I
have
confirmed.
We
gmr
are
now
a
network
with
over
92
percent
of
the
air
transports
we
provide
in
the
state
of
kentucky.
We
are
pleased
to
be
contracted
with
both
the
largest
commercial
insurance
companies
in
kentucky
anthem,
blue
cross,
blue
shield
and
united
health
care,
providing
in-network
coverage
to
83
of
the
commercially
insured
members
in
kentucky.
I
doubt
our
competitors,
like
our
methods,
have
in-network
numbers
nearly
as
good
as
with
ours.
If
they
are
here,
we
would
encourage
you
to
ask
them
our
ambulance.
E
Membership
is
a
prepaid
plan
that
covers
any
deductibles,
co-pays
and
co-insurance
requirements.
If
a
member
is
transported
by
a
gmr
company,
we
clearly
understand
the
facts,
as
outlined
by
the
kaiser
family
foundation,
which
indicates
average
cost
sharing
for
a
family
has
increased
by
70
percent,
with
both
employer
and
employee
spending
increasing
faster
than
workers
wages.
E
E
Our
members
have
the
financial
peace
of
mind
of
knowing
that,
if
one
of
our
ambulance
teams,
transport
them,
which
request
requested
based
on
state
protocols,
they'll,
have
no
out-of-pocket
costs
for
that
transport
as
clearly
defined
in
our
standard
terms
and
conditions
which
members
acknowledge
during
the
enrollment
process.
We
don't
cover
transports
by
a
different
air
ambulance
company.
I
invite
you
to
visit
our
website
airmedcarenetwork.com
to
see
this
for
yourself.
E
Finally,
eriml's
memberships
do
not
constitute
the
business
of
insurance
under
the
mccarrick
mccarran
ferguson
act.
Global
medical
response
has
won
a
lawsuit
against
north
dakota
and
two
back-to-back
lawsuits
against
west
virginia
substantiating
states
cannot
regulate
air,
most
memberships
as
insurance
west
virginia's
attempts
failed
both
under
both
its
pre-existing
insurance
statutes
and
under
new
statutes
that
air
methods,
a
gmr
competitor,
help
them
specifically
craft
in
an
attempt
to
skirt
ada
preemption
membership
plans
serve
a
vital
role
for
rural
communities
and
they
are
consumer-friendly.
E
A
Thank
you
all
thank
you
for
being
here
and
your
testimony
this
morning.
I
guess
we
probably
yeah
chris.
If
you
don't
mind,
come
back
to
the
table
and
we
do
have
some
members
who
would
like
to
be
recognized
for
questions.
First
is
representative
frazier.
G
Thank
you
chairman.
I
noticed
that
commissioner
clark
is
she
still
available
on
online.
G
K
Yes,
representative
frazier,
the
department
of
insurance
did
support
the
legislation
that
you
introduced
last
year
on
this.
I
believe
it
was
the
end
call
model.
There
was
one
deviation
that
we
had
from
the
model,
and
that
was
on
the
response
time
to
on
complaints.
K
You
know
the
department
feels
a
responsibility
to
protect
consumers
and
to
educate
consumers
and
really
on
this
issue.
I
don't
know
if
that
there
is
a
complaint
on
one
of
these
memberships
who
who
do
they
go
to?
You
know
what
administrative
body
to
the
point
are
these
fully
insurance
companies?
Do
they
happen
to
have
a
certificate
of
authority
in
the
commonwealth?
K
We
would
certainly
have
to
look
at
it
close
closer,
but
I
would
think
as
global
has
described
it.
Perhaps
that's
not
the
case.
However.
There
is
a
process
of
registering
with
the
department
which
is
not
a
full-line
certificate
of
authority.
It's
a
registration
similar
to
pharmacy
benefit
managers
or
utilization
review
entities,
and
that
would
give
the
department
the
ability.
Should
there
be
a
complaint
on
this
membership
that
we
could
administratively
review.
It.
G
A
Thank
you,
representative.
Kirk
mccormick
has
a
question.
Q
Thank
you,
I
think
it's
my
signal
that
comes
and
goes.
I've
had
an
opportunity
to
research.
This
issue
a
little
bit
and
I
just
kind
of
want
to
give
you.
I
have
a
question.
Q
R
This
is
correct,
representative
mccormick.
We
would
respectfully
disagree.
I
think
there
has
been
litigation
on
this
in
various
states.
You
know
there's
very,
very
strong
arguments
on
either
side.
However,
our
beliefs
that
the
mccarran
ferguson
act
was
put
in
place
to
allow
state
legislatures
to
regulate
the
business
of
insurance.
R
R
Q
Q
Q
Q
I'm
going
to
be
looking
at
it
much
closer.
My
son
is
in
paramedic
school,
he
works
weekends
as
an
emt,
and
you
know
we
talk.
We
have
a
regular
relationship
communication
about
his
job
and
his
goal
is
to
be
a
flight
paramedic.
Q
So
you
know,
I
know
that
I've
watched
over
the
period
of
the
last
10
to
15
years
and
it
seems
like
they're
very
busy,
there's
more
medevacs
out
of
our
little
county
per
week.
Now
don't
know
what
there's
ever
been.
So
I
even
brought
up
the
question:
are
they
overusing?
Q
You
know
airbag,
and
you
know
that's
the
ground
call.
So
you
know
I
was
told
that
there's
no
incentive
for
the
ground
people
to
call
in
a
medevac
unless
they
feel
that
it's
very
essential.
So
when
you
got
a
life
hanging
in
the
balance.
Q
Q
Apologize
for
that
noise,
I'm
having
to
use
mcdonald's
wi-fi
in
the
parking
lot.
So
just
I'm
going
to
be
looking
at
it
closely
and
I
had
to
just
encourage
everybody
else.
I
respect
representative
frazier.
I
trust
her
judgment.
She's
always
been
sound
and
rational.
Q
A
A
A
moment
ago
somebody
referenced
encoil
and
and
the
meeting
that
some
of
us
will
be
attending
next
next
week
over
the
past
week
or
so
there
was
a
letter
that
went
out
and
it
might
have
gone
out
to
all
two
hundred
and
eighty
seven
thousand
member
kentucky,
but
it
was
it
referenced
the
encoil
letter
and
asked
them
to
reach
out
to
us,
and
I'll
paraphrase
I
don't
have
a
copy
of
it,
but
it.
A
It
basically
said
that
if
encore
were
to
pass
that
bill
or
if
we
were
to
pass
a
bill
in
kentucky
memberships
would
no
longer
be
available,
they
would
be
outlawed
in
a
sense
can,
can
you
address
that?
Can
you
point
out
where
you
believe
that
either
in
the
encore
language
or
in
the
kentucky
model,
that
up
on
passage
memberships
will
no
longer
be
available?
I
can
address.
E
It,
yes,
sir,
can
you
hear
me
specifically?
Our
product
is
not
an
insurance
product,
so
you
know
regulating
us
or
creating
a
bill
that
says
it
is
an
insurance
product.
You
obviously
have
a
different
opinion
there
that
we're
not
an
insurance
product,
we're
also
not
an
insurer,
so
anything
that
changes
or
affects
us
to
become
an
insurance
product
or
insurer
could
jeopardize
our
ability
to
offer
membership
to
kentucky
residents.
E
So
obviously,
we'd
have
to
go
back
and
take
a
look
at
the
business
model
and
how
we
go
through
the
business
model
and
the
cost
incurred
with
those
changes.
So,
yes,
we
are
aware
of
that
letter.
We
did
notify
our
members
because
it
is
their
consumer
choice,
they're
buying
these
things
because
they
see
value
in
them.
The
representative
earlier
made
some
very
critical
points.
The
2500
to
some
is
real
money,
that's
a
significant
impact
to
them.
She
also
referenced
the
household
plan
and
that's
very
important
with
the
membership
product.
E
E
So
the
pure
research
group
right
now
shows
there's
70
000
or
excuse
me:
70
million
non-traditional
household
members
across
the
nation.
This
is
where
a
very
big
value
of
our
membership
product
comes
into
play
because
we're
covering
any
and
all
people
that
live
underneath
that
residential
roof
for
85
or
less
a
year.
A
Thank
you
and
I'll,
follow
the
question
and
I'll.
Let
we
have
some
other
folks
that
want
to
have
some
questions
here,
but
just
so
I'm
clear.
So
if
this
state
or
any
other
state
passed
a
bill
that
said
this
is
an
insurance
product.
You
got
to
report
to
the
department
you
got
to
be
transparent.
You
got
to
you
got
to
get
a
certificate
of
authority
to
to
transact.
You
would
probably
not
want
to
do
business
in
those
states
upon
passage.
E
We'd
have
to
reevaluate
that
we'd
have
to
evaluate
the
impact
on
the
business
and
what
type
of
changes
it
would
cause
the
product
itself.
As
far
as
consumer
protections,
we've
always
been
about
consumer
protection.
If
that's
the
goal
of
the
bill,
we
fully
support
that
we
have
it
in
coil
in
multiple
other
states,
our
terms
and
conditions
and,
for
example,
if
you
look
at
wyoming,
they
actually
took
our
advice
significantly
and
used
our
product
as
a
model
to
distribute
that
type
of
consumer
protection.
So
we
address
things
such
as
medicaid
as
referenced
earlier.
E
You
know
asking
somebody
to
validate
and
confirm
whether
they
are
on
medicaid
or
not,
so
we
can
advise
them
that
they
don't
have
a
need
to
purchase
a
membership
of
their
own
medicaid.
You
know
if
it's
going
down
the
path
of
where
it's
going
to
be
defined
as
an
insurance
product.
We
disagree
that
it
is
not
an
insurance
product
and
we
are
not
an
insurer.
E
A
Thank
you,
we'll
move
on
to
senator
gerdler.
N
Thank
you,
chairman.
First
of
all,
I'd
like
to
make
a
comment
I'll,
try
this
time
not
to
offend
a
legislator
as
a
life
experience
of
a
parents
of
two
girls
and
a
boy.
So
if
I
offended
anyone
else,
I'm
sorry,
but
that's
my
life
experience
as
a
parent
of
two
girls
and
a
boy
all
right.
R
E
We
would
disagree.
Obviously,
the
the
airline
deregulation
act
actually
has
the
preemption
built
in
there
that
it
is
controlled
at
the
federal
level.
There
are
opportunities
for
consumers
to
file
complaints
at
the
state
attorney
general
level.
If
there
are
any
complaints,
we're
eager
to
know
about
them,
we
we
take
great
pride
in
our
customer
interaction
and
how
we
treat
and
engage
with
our
customers.
That's
why
the
majority
of
our
members
are
exceedingly
retained,
retaining
to
us
at
87
or
higher
year
over
year.
E
They
see
value
in
the
product,
they
enjoy
the
experience
with
us
and
we
do
our
best
to
be
as
transparent
as
possible.
Make
sure
they
understand
if
membership
can
provide
a
value
to
them,
that
this
is
what
that
value
could
be
again
we're
unaware
of
any
complaints
at
the
state
level,
and
we
would
be
happy
to
hear
those
if
they
are
so.
We
could
address
those
individually.
N
With
the-
and
this
is
probably
for
representative
frazier
or
even
the
department
of
insurance
in
selling
a
product
and
me
being
in
the
insurance
business
for
so
long,
you
have
to
have
actuaries
to
figure
what
this
product
would
sell
for
and
are
they
other
states
that
have
this
product
that
has
actuaries
to
know
what
price
to
sell
and
then
would
it
be
a
writer
that
you
can
exclude
or
include
in
a
health
policy?
N
Would
it
like
if
it's
a
group
policy-
and
you
say
yes,
I
want
to
add
airmag
air
meds
on
r
and
then
also
another
thing
I
have
and
we're
talking
about
memberships.
N
N
E
Senator
thank
you
for
that
question
on
the
knowledge
of.
If
a
state
has
any
thing
instituted
to
control
pricing
on
membership,
we're
unaware
of
any
of
that.
We
don't
know
of
any
single
case
of
that.
E
E
So
what
we're
doing
to
our
consumers
is
we're
offering
a
prepaid
debt
relief
option
so
they're
buying
it
in
advance
in
the
event
that
they
utilize
those
services,
no
matter
what
happens
as
long
as
it's
one
of
our
participating
aircraft,
we're
going
to
eliminate
any
debt
that
their
insurance
may
not
cover.
This
is
any
and
all
insurances
as
referenced
earlier,
where
somebody
referenced,
you
know
an
auto
insurance,
homeowners,
insurance
and
medical
things
of
those
natures.
This
is
what
membership
does
in
today's
time.
The
feedback
we
get
from
our
consumers
is
very,
very
specific.
E
Understanding.
Insurance
is
extremely
complex,
as
we
heard
from
the
previous
testimony,
it's
very
very
difficult
for
them
to
understand
what
their
actual
financial
obligation
is.
Membership
serves
as
a
stability
piece,
no
matter
what,
if
they
utilize
a
service,
no
matter
if
their
insurance
changes,
if
they
go
from
commercial
to
private,
to
federal
to
uninsured,
which
is
a
significant
population,
they
are
going
to
owe
nothing
on
the
back
end
to
us.
So
we're
going
to
write
all
that
off.
N
You
know
the
the
one
of
the
things
in
experience
is
car
car
wrecks.
You
know,
that's
that's
where
you
get
a
lot
of
this
and
that's
where
you
get
the
reason
that
somebody's
knocked
out
on
the
pavement.
You
don't
have
a
clue
whether
they've
got
air
methods
or
airvac
or
whatever.
You
know,
that's
one
of
the
big
problems
but
yeah.
N
If
it's
going
to
be
sold
as
a
product,
is
there
somewhere
out
there
that
this
product,
that
kentucky
can
look
at
to
see
how
it
would
be
priced
and
what
it
would
cost
us
on
on
the
what
it
would
cost
the
consumer,
and
I
know
that
our
health
insurance
industry
has
our
health
insurance
companies
has
in-network
with
a
lot
of
them
and
so
therefore
they're
paid?
R
You
know
one
of
these
risks
that
you
speak
of
so
after
january
1st.
We're
really
only
concerned
with
copays
co-insurance
and
deductible
payments
for
those
individuals
that
have
any
form
of
healthcare
insurance.
I
think
another
thing
that's
very
important
to
to
touch
on
is
that
air
methods
like
gmr.
I
think
we
both
are
totally
aligned
on
this.
We
are
very
concerned
about
the
financial
impact
that
our
services
may
have
on
consumers.
R
I
think
how
we've
addressed
that,
however,
is
very
different.
Air
methods
offers
a
patient
advocacy
program
that
works
with
patients
to
understand
you
know
their
financial
ability
to
pay.
If
any,
we
have
a
robust
charity
care
program
that
routinely
examines
patients
financial
conditions
to
see
if
they're
able
to
pay
and
if
they're
not,
then
that
balance
is
written
off
under
that
charity
care
program.
R
My
understanding
and
I
would
represent
to
this
committee
and
I'm
sure
I'll,
be
corrected
if
I'm
wrong,
that
the
gmr
has
a
very
similar
program
and
their
average
out
of
pocket
is
less
than
260
dollars.
So
I
think
when
we
think
about
the
threat
of
copays
and
coinsurance
and
deductibles,
we
would
agree
that
a
copayment
or
coinsurance
of
five
thousand
dollars
or
seven
thousand
dollars
is
very,
very
high,
and
that's
why
we
put
these
programs
in
place
to
ensure
that
we're
not
putting
a
financial
burden.
E
J
J
I
apologize
and
I'm
trying
to
get
everybody
out
here,
so
I,
but
I
want
to
be
clear
on
what
what
we're
going
to
be
doing,
because
this
is
going
to
be
brought
up
and
we're
going
to
have
to
make
a
decision
on
on
legislation.
I
want
to
make
sure
I'm
clear
on
the
way
that
I'm
looking
at
it.
The
first
territories
and
people
are
disgruntled
with
territories.
J
I
understand
that,
but
when
there's
not
any
disgruntle
and
we're
asking
for
a
private
to
be
placed
under
a
government
oversight
that
bothers
me,
because
if
it,
if
we
start
with,
say
your
company,
where
is
it
going
to
end
at
we're,
going
to
start
penetrating
the
private
sector
and
find
more
and
more
to
bring
under
regulation
of
our
state
and
federal
governments?
And
I
understand
what
you're
trying
to
say
that
federal
has
already
picked
this
up.
But
let's
see
where
it
goes.
J
Well,
my
people's,
not
asking
for
it
now.
If
you
want
to
go
down
there
and
drum
them
up
and
get
a
beat
going,
then
let's
talk
about
it,
but
don't
stir
them
when
there's
not
any
issue
in
my
area,
but
if
you're
trying
to
say
I'm
looking
after
them,
then
find
out
what,
where
they're
at
that
you're
that
we're
having
an
issue
with
and
because
I
haven't
heard
that
in
my
district
and
until
I
do,
I
can't
see
where
we
need
to
try
to
fix
something.
J
That's
not
broken
in
my
area,
man,
it
may
be
broken
in
other
parts
of
the
state
and
representative
frazier
may
have
an
issue
in
in
her
area
and
I'm
willing
to
listen
to
that.
If,
if
fairvac
or
whoever
these
other
providers
are,
are
really
giving
her
constituents
a
rough
way
of
going,
then
we
need
to
address
it.
I'm
for
protection,
but
I'm
not
for
creating
another
bureaucracy.
In
my
area.
That's
not
needed,
I
guess
is
what
I'm
trying
to
say.
J
We
know
that
if
it
goes
under
a
government
oversight,
there's
got
to
be
more
people
hired
to
keep
the
paperwork
filled
out
and
plus
they
have
to
charge
more
to
to
handle
that
situation.
So
I'm
not
trying
to
pick
winners
and
losers
here,
because
you
said
you
was
even
not
against
you.
Weren't
fighting
you
weren't
against
it.
Well
then
we're
on
the
same
page
there,
but
I'm
not
for
bringing
on
more
regulations.
It's
what
I'm
trying
to
say
or
bring
government
into
a
situation
when
it's
not
needed.
J
But
if
you
can
show
me
that
I've
got
constituents
being
mistreated
and
that
they're
they're
they're
having
a
a
rough
time
being
treated
the
way
they
are
with
this
membership
deal,
because
I
have
not
had
that
I've
had
only
positive
responses
to
saying
that
they
appreciate
being
able
to
have
that
membership.
J
So
again,
I
want
to
do
what's
best
in
and
if
the,
if
you
have
an
issue,
that's
even
in
the
other
part
of
the
state
where
people
are
really
being
mistreated,
I'm
willing
to
listen
to
it.
But
as
far
as
my
constituents
and
my
district,
if
it's
only
dealing
with
bringing
a
regulation,
mr
chairman
onto
a
situation
of
private,
then
I
have
a.
I
have
a
hard
time
of
adding
more
regulations
to
private
business,
and
I
want
to
make
sure
you
were
private
you're,
not
a
public
company.
J
I
want
to
make
sure
that
your
membership
is
a
part
of
your
your
the
basis
for
your
establishment
and
if
so,
then
I
just
wanted
to
make
sure
I
understood
that
part
of
it.
But
I
I
appreciate
you
listening
to
me,
but
that's
that's
basically
all
I
want
to
say
I
want
to
make
sure
I
wasn't
getting
involved
in
a
situation.
That's
not
in
my
area
that
we,
as
far
as
I
know,
we
don't
have
anybody
crying
for
help
in
the
membership
basis.
So
again,
thank
you,
mr
chairman,
for
the
time.
F
Thank
you,
mr
chairman,
and
my
question
is
going
to
be
when
I
get
to
it
here
in
just
a
minute
is
going
to
be
directly
for
commissioner
clark
and
I'm
going
to
divert
in
that
question
from
a
discussion
between
basically
two
competing
companies
who
have
very
different
business
models.
Frankly,
you
you
exist
with
very
different
business
models.
F
You
mentioned
territorial
issues
and
my
rural
community
that
I
represent
sits
kind
of
right
on
the
line
of
kind
of
two
different
territories
there
that
both
of
you
all
have
flight
bases
in
you
can
get
to
my
community
within
about
30
minutes
drive
from
your
flight
basis
of
either
of
your
companies,
and
so
in
my
community
you
may
get
a
helicopter
from
either
one
of
those
locations
at
any
given
time,
depending
on
what
the
the
airspace
looks
like
at
that
point,
depending
on
what
the
weather
is
determining
on
the
availability
or
any
of
those
things,
and
there
has
been
some
consternation
over
the
years
amongst
those
local
emergency
responders
on
the
ground
of
if
somebody
does
have
a
a
membership
with
one
company
and
they
end
up
getting
the
other
company
to
respond
because
they're
the
most
appropriate
responder,
but
based
on
time
or
whatever.
F
F
Now.
Moving
into
my
question,
though-
and
this
is
where
I'm
going
to
divert
from
the
two
companies
and
go
directly
to
to
commissioner
clark-
I
know
we
have
a
difficult
situation
here,
because
it's
it's
a
determination
of
is
this
something
that
you
can
regulate,
or
is
there
a
federal
preemption
under
the
faa
laws
because
of
the
membership
scenario?
F
I
also
know
there's
at
least
one
other
company,
and
maybe
multiple
companies
who
are
operating
in
state
selling.
What
is
a
membership
product
is
what
they're
they're
describing
it
as,
but
they
are
not
operating
any
aircraft
and
they
work
with
all
of
the
companies
or
that
is
what
they're
selling
when
they
sell
the
product
working
with
all
the
companies
to
pay
and
offset
the
cost
that
are
not
covered
by
insurance.
K
Well,
thank
you,
representative
meredith.
As
you
know,
for
three
years
and
the
department
has
received
complaints,
I've
been
a
commissioner
now,
I'm
working
on
my
10th
year.
We
have
had
complaints
throughout
the
years
on
the
surprise
billing,
primarily
this,
in
particular
scenario
that
you
mentioned.
K
Yes,
we
are
currently
reviewing
or
investigating
one
of
those
entities
that
you
described.
I
can't
say
anymore
at
that
time
on
that
with
regard
to
the
airline
deregulation
act,
that
that
has
been
an
issue
for
years
and
ten
years
ago.
You
know
we
would
have
concerns
with
the
the
ambulance
service
and
that
act
was
always
cited.
However,
specifically
in
the
no
surprises
act
that
has
been
eliminated
that
barrier,
and
so
we
do
think
that
that
would
be
an
advantage.
A
Thank
you,
representative
stevenson,.
B
Hello,
I
guess
I
technically
have
two
questions.
Sorry
chairman,
but
help
me
understand
from
what
you
have
explained,
and
this
was
primarily
it
started
out
because
of
balance
billing
and
now
that
the
gnosis
prizes
act
has
come
through
and
you're
shifting
into
prepayment
for
deductibles
co-payments,
all
that
kind
of
stuff.
How
has
that
been
communicated
to
your
customers
and
has
have
you
had
any
of
them
to
be
like?
Oh
well,
are
they
just
saying?
Oh,
this
is
great
or
are
any
of
them
saying?
Oh
okay,
so
maybe
I
don't
need
this
anymore.
E
Is
that,
for
me,
representative
sure?
Okay,
thank
you.
First
for
clarification,
it
wasn't
us
who
said
we
marketed
it
toward
balanced
billing.
It
was.
It
was
air
methods
that
said
that,
so
that's
inaccurate
we've
always
marketed
membership
toward
the
out-of-pocket
expenses
to
provide
the
financial
peace
of
mind
that
we
feel
our
patients
that
choose
to
be
members
deserve
the
complexity
behind.
It
is
even
though
the
no
surprise
act
comes
in
place,
which
is
great,
because
we've
been
a
huge
supporter
of
that
too.
That
takes
that
balance.
E
Bill
takes
the
patient
out
of
that
that
process
and
lets
the
insurance
carrier
and
the
provider
go
into
discussions
with
that.
It
still
doesn't
eliminate,
not
just
the
co-pays
that
are
referenced
but,
more
importantly,
the
co-insurances,
and
if
you
look
at
some
of
these
summary
benefit
guides
are
out
there.
Even
with
an
in-network
agreement,
patients
could
be
responsible
for
20
30,
40
50
on
their
co-insurance
side
of
it.
What
membership
does?
Is
it's
going
to
relieve
them
of
that
obligation
to
us
as
a
carrier?
If
we
have
transported
them?
Does
that
answer
your
question.
B
It
it
does
yes
and
if,
if
I
may,
one
more
so
as
you're
explaining
all
of
this
for
me-
and
I
am
not
an
insurance
person
so
so
I
will,
I
will
announce
that
up
front,
but
it
this
sounds
a
lot
like
kind
of
gap
coverage
to
me.
So
there's
a
lot
of
like
medigap
and
things
like
that
out
there.
So
how
do
you
differentiate
yourself
from
that
gap
coverage
and
how
does
that
then?
E
One
we're
relieving
debt
so
we're
not
we're
not
paying
out
anything
to
anybody,
we're
actually
providing
the
service
so
we're
not
paying
ourself
we're
not
paying
another
air
ambulance
provider.
So
that's
you
know
we're
not
indemnifying
ourselves.
In
that
sense,
the
next
thing
is
we're
not
guaranteeing
a
service.
We
can't
there's
no
hard
science
to
this
industry.
It's
very
unpredictable.
You
never
know
when
a
person
may
need
this
service.
You
know
it
could
be
an
event
that
they
may
have
called
themselves.
E
E
So
it's
it's
a
prepaid
debt
relief
product
for
our
members
alone,
so
we
have
absolute
control
over
it
on
the
mechanisms
that
are
internally
inside
of
it
where,
as
an
insurance
product,
you
know
if
it
was
another
company
and
we
offered
that
we
would
pay
dues
to
that
for
those
services
rendered.
We
don't
do
that.
G
Thank
you
chairman.
I
just
have
a
comment
in
regards
to
your
concern.
I
think
really
I
mean
there's
so
few
complaints,
because
we
have
to
remember
there's
only
one
tenth
of
one
percent
of
these
policies
that
are
ever
being
used
so
that
to
me
the
no
complaint
issue
is
kind
of
like
a
red
herring.
It
would
be
almost
like
buying
a
lottery
ticket,
not
winning
the
lottery
and
then
complaining
that
you
didn't
win.
So
that's
how
I'd
like
to
respond
to
that.
D
Thank
you,
mr
chairman,
here
in
rural
kentucky
up
here
in
eastern
kentucky.
Sometimes
we
have
trouble
with
the
ambulances
that
are
on
the
roads.
T
We
are,
we
are
like
a
flying,
icu
or
emergency
room.
I
I
don't
know
that
I
would
say
that
we
have
every
ability
that
an
emergency
department
has
other
than
x-ray
or
radiology,
but
we
do
have
all
of
the
critical
care
drugs.
We
have
a
licensed
critical
care,
paramedic,
critical
care
nurse,
two,
two
caregivers
taking
care
of
the
patient
one
patient
at
a
time-
and
we
do
have-
we
do
have
the
cardiac
monitors.
We
have
the
defibrillators
iv
pumps
ventilators,
all
of
those
types
of
equipments
that
you
would
need
for
emergency
resuscitation.
T
D
Well,
I
think
there
is
value
in
that
helicopter.
Then
it's
similar
to
emergency
room.
It
gets
there
quickly
for
the
people
in
rural
kentucky
and
it
can
warm
an
iv
for
an
infant.
That's
a
lot
of
care
right
there
in
one.
What
are
those
bail
helicopters?
I
think
they
are
that
you
all
use,
so
I
just
want
to
show
the
value
that
helicopter
is
to
the
rural
areas
of
kentucky.
Thank
you,
mr
chairman.
A
Thank
you,
representative
representative
mcpherson
has
a
commenter
a
question.
D
Yes,
it's
more
of
a
comment:
I've
sat
here
and
kind
of
listen
to
all
the
pros
and
cons
here.
We've
got
a
bill.
That's
going
into
effect
in
52
days.
You've
got
287
000
members
that,
as
long
as
we
have
full
disclosure,
it
looks
like
the
free
market
system
will
take
care
of
itself.
D
If
you
all
don't
provide
the
right
product
and
if
and
if
everybody
goes
out
with
full
disclosure
and
there's
no
need
for
this
product,
then
you
will
go
away,
but
if
you
don't
and
people
continue
to
buy
it,
then
there's
value
in
it.
So
it
looks
like
to
me
that
the
fire
market
system
is
acting
and
will
continue
to
act.
Thank
you,
mr
chairman.
A
Thank
you
and
looks
like
the
last
question
or
comment
this
morning
will
come
from
representative
lewis.
H
Thank
you,
mr
chairman.
We
have
been
working
on
this
for
quite
some
time.
Chairman
several
other
members.
We
go
to
encore
quite
often
have
a
great
time
and
really
do
important
work
with
that,
and
so
on
this
issue
you
know
I
was
under
the
same
impression
that
representative
meredith
had
that
you
know
when
the
surprise
billing
act
passed,
that
a
lot
of
these
issues
would
be
resolved,
and
I
don't
know
I
I
guess
I'll
just
take
issue
with
with
how
this
is
being
approached.
H
You
know,
we've
we've
put
a
lot
of
effort
and
an
incoil
actually
offered
an
amendment
myself
to
address
a
lot
of
these
concerns,
but
best
I
can
tell
we
have
one
company
who
is
pushing
across
the
nation
legislation.
H
That's
gonna
impair
another,
their
competitor's
business
model,
and
you
know,
as
representative
meredith
said
before,
these
are
two
very
different
models,
and
so
I
was
just
kind
of
glancing
doing
some
research.
While
I
was
sitting
here-
and
I
see
air
methods
discontinued
membership
services
in
2009,
so
I
guess
that
didn't
work
for
them.
D
H
They
have
17
bases
in
kentucky,
one
being
in
clay,
county
and
clay
county.
This
group
is
a
community
partner.
You
know
you
see
the
stickers
on
the
back
of
vehicles,
you
see
them
sponsoring
games,
you
don't
hear
volume
of
complaints,
but
no
you,
you
see
these
people
as
a
community
partner
and
they
work
with
their
local
hospitals.
H
So
going
on,
I
kept
researching
and
I
try
to
find
something
about
a
patient
another
state
refusing
care
because
it
wasn't
part
of
the
service
best.
I
could
tell
I
couldn't
find
anything
on
that,
but
I
did
get
on
air
methods
website,
and
so
I
went.
R
H
And
I
came
across
a
section
that
said
membership
deception,
where
they
call
their
competitors
money,
making
fraudsters,
and
so
I
guess
I
just
take
issue
with
using
this
legislative
body
to
impair
another
private
business,
and
I
take
issue
with
that.
There's
still
a
lot
of
issues
out
there.
Federal
versus
state,
faa
control
points
great
points
bait
on
both
sides,
but
at
the
end
of
the
day,
governments
should
not
be
picking
winners
and
losers.
Thank
you,
mr
chairman.
A
Thank
you
any
other
member
seeking
recognition
on
this
topic
or
anything
else.
This
morning,
representative,
frazier.
G
Yes,
I
would
just
like
to
comment
because
I've
heard
it
said
many
times.
You
know
that
you're
relieving
members
of
having
to
pay
their
own
deductibles
and
co-pays
and
to
me
that's
the
definition
of
insurance.
So
thank
you.
A
Thank
you
well
appreciate,
all
of
you
being
here
this
morning.
This
continues
to
be
a
very
robust
discussion,
both
here
and
and
at
end
coal,
and
I
know
in
other
states,
so
I'm
sure
we
will
continue
to
talk
about
this
issue
and
see
how
things
evolve
after
in
52
days
and
again,
we
thank
you
for
your
time.
Thank
you.
Thank
you
to
the
committee
for
your
participation
and
I
will
adjourn
the
meeting.