Committee Statement to Senate, No. 3218 with committee amendments - Senate Commerce Committee (December 14, 2020)

Summary

A statement of the Senate Commerce Committee to the Senate on Senate Bill No. 3218 with committee amendments, of the State of New Jersey, dated December 14, 2020. The committee reports the bill favorably and with committee amendments. As amended, the bill provides for the reorganization of a health service corporation. It states that a mutual holding company organized under the bill may not be established as a company organized for pecuniary profit and retains the designation as a charitable and benevolent institution. The existing exemption from taxes other than taxes on real estate and equipment and taxes on premiums continues to apply if the mutual holding company continues to participate in the New Jersey Individual Health Coverage Program and the New Jersey Small Employer Health Benefits Program.

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     SENATE COMMERCE COMMITTEE

                     STATEMENT TO

                   SENATE, No. 3218
                    with committee amendments



 STATE OF NEW JERSEY
                   DATED: DECEMBER 14, 2020

    The Senate Commerce Committee reports favorably and with
committee amendments Senate Bill No. 3218.
    As amended, this bill provides for the reorganization of a health
service corporation.
    The bill provides that a mutual holding company organized
pursuant to the bill may not be established as a company organized for
pecuniary profit and retains the designation as a charitable and
benevolent institution pursuant to current law. A mutual holding
company established pursuant to the bill retains the health service
corporation’s mission while supplementing that mission to promote
innovation and delivery of diversified services.
    The bill provides that mission of the mutual holding company is to:
    (1) provide affordable and accessible health insurance to its
members;
    (2) promote the integration of the health care system to meet the
needs of its members; and
    (3) promote innovation and delivery of solutions and diversified
services for its members.
    Other than as otherwise provided, the bill provides that all
property, assets, rights, liabilities, interest and relations of whatever
kind of the health service corporation, and its subsidiaries, will be that
of the mutual holding company system. The mutual holding company
is no longer considered a health service corporation. Notwithstanding
anything to the contrary, the provisions of current law that exempt
health service corporations from taxes other than taxes on real estate
and equipment and taxes on premiums continue to apply to a mutual
holding company if the mutual holding company continues to
participate in the New Jersey Individual Health Coverage Program and
the New Jersey Small Employer Health Benefits Program. If the
mutual holding company does not continue to participate in the New
Jersey Individual Health Coverage Program and the New Jersey Small
Employer Health Benefits Program, then the mutual holding company
shall no longer be exempt from those taxes.
    Under the bill, certain health insurance duties and obligations
pursuant to current law continue and remain in the succeeding
reorganized insurer.
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    The mutual holding company is excluded from certain insurance
operations and reporting, investment limits, and risk-bearing
provisions of the health service corporation law, because the mutual
holding company is not a risk-bearer.
    The bill provides that the reorganized insurer shall engage in risk-
bearing activities, reporting, investments, financial transactions,
including the issuance of dividends or distributions, and insurance
trade practices consistent with laws governing stock insurance
companies organized under Title 17B of the New Jersey Statutes to
transact health insurance. The bill also provides that certain provisions
of the health service corporation law do not apply to the reorganized
insurer or any insurance company or risk-bearing entity within the
mutual holding company system.
    The bill provides that the insurance premium rate tax cap law
provided pursuant to current law shall apply to the companies within
the mutual holding company system that have an insurance premium
tax liability, and the exclusion from the tax cap applicable to a health
service corporation shall not apply to the mutual holding company or
any entity within the mutual holding company system, including the
reorganized insurer, that has an insurance premium tax liability.
    The bill provides that a mutual holding company system may
pursue businesses, assets, or operations through one or more of its
insurance subsidiaries and non-insurance subsidiaries without a limit
on aggregate revenues from nonconforming affiliates or those pursuits
being considered a material change in form. The subsidiaries of the
mutual holding company, including the reorganized insurer, may make
dividends or distributions to the mutual holding company, any
subsidiaries thereof, or both, and not be considered a material change
in form. Dividends and distributions from domestic insurers, including
the reorganized insurer, within the mutual holding company system are
subject only to certain applicable provisions of current law.
    The bill provides that a health service corporation may reorganize
to create a mutual holding company system pursuant to a plan of
reorganization at the same time it applies to transition to a mutual
insurer. Thereafter, the succeeding mutual holding company system
shall be operated in a manner consistent with the provisions of the bill.
    The bill requires the mutual holding company system to consist of
a mutual holding company and one or more controlled nonprofit or
for-profit subsidiaries, including the reorganized insurer, and to be
operated for the benefit of its members.
    The bill provides that the mutual holding company and each of its
non-insurance subsidiaries, other than the reorganized insurer and any
insurance company subsidiaries, shall not be:
    (1) an insurer and therefore shall not be subject to any of the
provisions of current law applicable to stock or mutual insurers, or to
any laws concerning the writing of insurance, including rules and
regulations adopted thereunder, including with respect to governance,
                                  3

stock or other voting or equity interest, the writing of insurance, any
investment limitations directly applicable to risk-bearing entities
engaged in the writing of insurance, or any capital or surplus
requirements;
    (2) authorized to transact the business of insurance; or
    (3) qualified as an insurer.
    The bill provides that the writing of insurance is permitted only
through the reorganized insurer and other insurance company
subsidiaries or investments of the mutual holding company. Nothing
in the bill alters the oversight of the commissioner with respect to the
mutual holding company and its non-insurance subsidiaries provided
for under applicable laws and rules of this State relating to insurance
holding company systems.
    The bill requires a mutual holding company to be a nonprofit entity
incorporated under, and to conduct its business pursuant to, the
provisions of Title 15A of the New Jersey Statutes, except that in
situations in which the provisions of that title are inconsistent with the
provisions of the bill, the provisions of the bill shall govern.
    The bill provides that, at the effective time, members shall receive
membership interests of the mutual holding company, and thereafter
100 percent of the membership interests of the mutual holding
company shall continue to be held by members, in each case, in the
manner set forth in the articles of incorporation and bylaws of the
mutual holding company.
    The bill requires the shares of the capital stock of the reorganized
insurer to be:
    (1) issued to the mutual holding company or one or more
intermediate holding companies that are wholly-owned by the mutual
holding company; and
    (2) at all times owned by the mutual holding company or one or
more intermediate holding companies that are wholly-owned by the
mutual holding company.
    The subsidiaries of a mutual holding company system may be
formed by any of the following means:
    (1) the formation of one or more subsidiaries;
    (2) amendment or restatement of the articles of incorporation and
bylaws of one or more companies;
    (3) transfer of assets and liabilities among two or more companies;
    (4) issuance, acquisition or transfer of capital stock of one or more
companies; or
    (5) merger or consolidation of two or more companies.
    The bill provides that the mutual holding company is to ensure that
any ownership interest in a subsidiary is held by the mutual holding
company and any profits generated by that interest are returned to the
mutual holding company.
    The bill provides that a health service corporation may submit an
application to the commissioner to form a mutual holding company
                                 4

system. Upon submission of an application to the commissioner, a
health service corporation shall immediately thereafter provide a copy
of the application to the Attorney General. Prior to submission of the
application, the board of directors of the health service corporation
shall adopt a resolution proposing to transition to a mutual insurer and
form a mutual holding company system, at a meeting of the board by a
two-thirds affirmative vote of the total number of directors of the
health service corporation. A copy of the minutes of the meeting at
which that resolution is adopted shall be filed with the commissioner.
The resolution shall include a plan to transition to a mutual insurer and
form a mutual holding company system, including proposed articles of
incorporation and bylaws for the mutual holding company and
proposed articles of incorporation, certificates of formation,
restatements of, or amendments to, existing articles of incorporation or
bylaws, and plans of merger or consolidation, with respect to each
entity to be formed, converted or otherwise subject or party to the
transition transactions pursuant to the plan of mutualization and
reorganization.
    The bill provides that, in addition to including information required
pursuant to current law for the plan of mutualization, with respect to
the formation of a mutual holding company system for purposes of this
provision, the plan shall include:
    (1) A description of the structure of the mutual holding company
system consistent with the requirements set forth in the bill;
    (2) A description of the qualifications for members’ membership
in, and the rights of members of, the mutual holding company
consistent with the requirements set forth in the bill;
    (3) A description of the transactions, and parties to those
transactions, that will affect the mutualization and reorganization,
including, but not limited to, transfer and assumption of policies,
contracts, assets and liabilities, formation of entities, and the
amendment or restatement of certificates of incorporation or bylaws.
The plan of reorganization may provide for the transfer of assets of a
health service corporation and its subsidiaries to the mutual holding
company or one or more subsidiaries of the mutual holding company
in connection with the formation of the mutual holding company
system;
    (4) The identity of those persons who shall serve as directors and
officers of the mutual holding company, its intermediate holding
companies, if any, and its subsidiaries, including the reorganized
insurer, as of the effective time of the mutualization and
reorganization. The plan shall specify the members of the board of
directors of the health service corporation who shall serve as initial
directors of the mutual holding company;
    (5) Information sufficient to demonstrate that the financial
condition of the reorganized insurer and the insurance company
subsidiaries of the reorganized insurer will meet solvency
                                  5

requirements pursuant to applicable laws and rules of this State
relating to insurance companies after giving effect to the mutualization
and reorganization;
    (6) A certification that, following the mutualization and
reorganization, policies shall remain in full force and effect under
policies transferred to and assumed by insurance company subsidiaries
of the mutual holding company;
    (7) A certification that, following the mutualization and
reorganization, the material terms and conditions of subordinated
surplus notes and other contractual obligations, with certain
exceptions, of the health service corporation and its subsidiaries shall,
subject to the rights of the health service corporation and its
subsidiaries under applicable law, and to the extent those obligations
are not otherwise satisfied or terminated in accordance with their
terms, remain in effect upon the transfer of those obligations to, and
assumption of those obligations by, the reorganized insurer or one or
more other subsidiaries of the mutual holding company; and
    (8) A certification that, following the mutualization and
reorganization, the mutual holding company shall comply with the
employment requirements as provided in the bill.
    The bill provides that, upon the affirmative vote of the board of
directors complying with the requirements of the bill, the plan to form
a mutual holding company system shall be filed with the commissioner
for approval. Upon filing the plan to form a mutual holding company
system, the obligations pursuant to current law shall be suspended
during the pendency of the commissioner’s review process. If the
commissioner approves the plan to form a mutual holding company,
certain obligations arising pursuant to current law shall be deemed
satisfied by the initial assessment required by the bill.
    The bill requires the commissioner to review the plan to mutualize
and reorganize in accordance with the requirements of current law and
the bill, including requirements for three public hearings.
    The bill requires the commissioner to approve a plan of
mutualization and reorganization unless the commissioner finds the
plan:
    (1) is contrary to law;
    (2) would be detrimental to the safety or soundness of the
proposed reorganized insurer and insurance company subsidiaries of
the proposed mutual holding company; or
    (3) does not benefit the interests of the policyholders of the health
service corporation or treats them inequitably.
    The bill provides that the commissioner may engage the services of
experts and consultants to advise on any matters related to the
application, and if a written study or other expert report is prepared, it
is to be made available to the applicant within a reasonable period of
time prior to the initial public hearing. Pursuant to the bill, the
commissioner may also engage the services of a consultant to conduct
                                  6

a health impact study of the effects of the reorganization on the health
of the policy holders of the health service corporation, and the general
public. The engagement shall not be subject to Chapter 32 of Title 52
of the Revised Statutes and all costs related to such engagement for the
examination and deliberations of the application shall be paid by the
health service corporation that makes the filing, both for services prior
to the effective time and for services after the effective time. At the
expiration of 30 days after the final public hearing, the commissioner
shall approve or disapprove the plan of mutualization and
reorganization and shall set forth the decision in writing and shall state
the reasons therefor. The commissioner shall inform the health service
corporation of the specific reasons for the disapproval of any plan of
mutualization and reorganization and provide a cure period of no
shorter than 90 days to cure any deficiencies. Any disapproval shall
be subject to judicial review as a final decision of a State
administrative agency.
    The bill provides that a plan of mutualization and reorganization
may be amended, terminated, or approved. A plan of mutualization
and reorganization adopted by the board of directors of the applicant
may be:
    (1) Amended by the board of directors of the applicant in response
to the comments or recommendations of the commissioner at any time;
or
    (2) Terminated by the board of directors of the applicant at any
time. An applicant that has terminated a plan to form a mutual holding
company system shall be deemed to have also terminated the
application to transition to a mutual insurer.
    The bill provides that an approved plan of mutualization and
reorganization is effective at the effective time specified in the plan of
reorganization, or such other time subsequently requested by the
applicant and agreed to by the commissioner.
    The bill provides that a mutual holding company system is
considered an insurance holding company system and subject to the
current law governing insurance holding company systems, with
certain exceptions. In addition, the bill provides that the commissioner
possesses supervisory powers with respect to the insurance holding
company system which shall include the authority to monitor the
mutual holding company systems financial health, enterprise risk, and
exam its operations pursuant to P.L. 1970, c.22 (C.17:27A-1 et seq.).
    The bill allows a mutual holding company or a non-insurance
subsidiary to make any lawful investments including directly or
indirectly acquiring or otherwise holding the stock or other ownership
interests of any nonprofit or for-profit entities. Insurance company
subsidiaries and the reorganized insurer may make investments,
including investments in non-insurance entities subject to investment
and asset limitations pursuant to applicable laws and rules relating to
insurance companies.
                                 7

    The bill requires the mutual holding company and its non-
insurance and insurance company subsidiaries to continue to operate a
diverse supplier program that promotes and invests in the utilization of
minority-owned and women-owned businesses in the procurement of
goods and services, including professional services.
    The bill provides that the application submitted pursuant to the bill
be a public record, except for certain confidential documents which
shall not be public records. The commissioner is to provide the public
with prompt and reasonable access to public records relating to the
proposed reorganization of the health service corporation.
     Neither the adoption nor the implementation of a plan of
mutualization and reorganization pursuant to the bill is deemed to give
rise to any obligation by or on behalf of any entity in the mutual
holding company system or any predecessor entity to make any
distribution or payment to any member or policyholder, or to any other
person, fund, or entity of any nature whatsoever, in connection with
the ownership, control, benefits, policies, purpose, or nature of any
entity in the mutual holding company system, any predecessor entity
or otherwise.
     Under the bill, membership in a mutual holding company is to be
determined in accordance with the mutual holding company’s articles
of incorporation and bylaws and may be based upon:
     (1) the amount of health insurance policies in force with the
reorganized insurer;
     (2) the amount of the health insurance premiums paid to the
reorganized insurer; or
     (3) other reasonable factors.
     A mutual holding company may also consider the amount of
premiums paid to, or policies in force under, affiliated insurance
companies operating under the same brand licensee program as the
reorganized insurer and permit entities holding administrative services
agreements with the mutual holding company to be members of the
mutual holding company. The mutual holding company may provide
in its bylaws the basis for the number of votes those entities will have
as members of the mutual holding company.
     A mutual holding company formed pursuant to the bill may not
convert to a for-profit stock holding company. The provisions of
current law providing for conversion of a health service corporation to
a domestic stock insurer do not apply to a mutual holding company
formed pursuant to the bill.
     The bill provides that members of a mutual holding company shall
be entitled to vote for the election of directors of the mutual holding
company in accordance with the mutual holding company’s bylaws.
Directors of the mutual holding company shall be elected from
nominees selected by the nominating and governance committee of the
board of directors of the mutual holding company, or a comparably
                                 8

authorized committee, except for public directors serving in
accordance with the provisions of the bill.
     The bill prohibits a member of a mutual holding company from
transferring membership or any right arising therefrom.
     Upon any voluntary dissolution of a mutual holding company in
accordance with current law, the mutual holding company shall adopt
a plan of dissolution. The plan shall provide for distribution of any
assets of the mutual holding company remaining after the discharge of
all liabilities and obligations.
     The bill requires a mutual holding company to file with the
commissioner an annual statement pursuant to applicable laws of this
State.
     Following approval of a transition pursuant to the bill, and the
establishment of a mutual holding company, the mutual holding
company, or any affiliates benefiting from the establishment of a
mutual holding company, shall pay an initial assessment to the State
Treasury in the amount of $600,000,000 by June 1, 2022 if the
effective time precedes June 1, 2022. If the effective time is later than
June 1, 2022, the initial assessment shall be due by June 1 of the
calendar year following the effective time. The initial assessment shall
be a one-time, nonrecurring State business tax on the mutual holding
company and its affiliates.
     Following the initial assessment, the mutual holding company, or
any affiliates benefiting from the establishment of a mutual holding
company, shall pay a limited duration business tax by June 1 of each
calendar year beginning with the calendar year following the initial
assessment, and for a period of seventeen years. The total assessment,
including both the initial and annual assessments, shall not exceed
$1,250,000,000. The annual assessments represent a limited duration
state business tax on the mutual holding company and its affiliates
business payable by the mutual holding company or any affiliates
benefiting from the establishment of a mutual holding company, and
shall be based on the following schedule with earned premiums
defined consistent with 45 CFR 158.130:
     (1) For annual assessment 1, 20 percent of the reorganized
insurer’s earned premiums for the calendar year preceding that
assessment, with the assessment not to exceed $100,000,000.
     (2) For annual assessments 2 through 11, 5 percent of the
reorganized insurer’s earned premiums for the calendar year preceding
a given year’s assessment, with each year’s assessment not to exceed
$25,000,000.
     (3) For annual assessments 12 through 17, 10 percent of the
reorganized insurer’s earned premiums for the calendar year preceding
a given year’s assessment, with each year’s assessment not to exceed
$50,000,000.
     The bill provides that the mutual holding company shall not pay
any portion of the annual assessment for a given calendar year if the
                                 9

mutual holding company’s system-wide health risk-based capital
authorized control level would fall below 550 percent based on the
standards for risk based capital for health organizations as adopted by
the National Association of Insurance Commissioners following the
payment as applied against the prior calendar year’s risk based capital,
or if in the opinion of any nationally recognized statistical rating
organization, the group credit rating of the mutual holding company
would not be considered investment grade. The commissioner is to
determine that the mutual holding company’s system-wide health risk-
based capital authorized control level would fall below 550 percent
before payments are to be deferred pursuant to the bill. Neither the
insurance company subsidiaries nor the reorganized insurer are to
make dividends or distributions to the mutual holding company or any
subsidiaries thereof until such time as the annual assessment deferred
pursuant to the bill is satisfied.
    If the mutual holding company does not pay the annual assessment
for a given calendar year, the annual assessment that was not paid shall
be deferred to the subsequent calendar year, which shall be the deferral
date for the deferred annual assessment, with all subsequent annual
assessments also deferred by another calendar year so that no two
annual assessments are due in the same calendar year. If an annual
assessment is deferred, that annual assessment shall not be required by
law to be paid until the deferral date.
    Notwithstanding the provisions of the bill to the contrary, the
assessment years shall not be extended beyond, and the payment
obligation shall cease to exist after, the date that is 25 years from the
effective time.
    The bill provides that the board of the mutual holding company
shall be constituted of 22 directors as follows:
    (1) 13 directors shall be elected, as provided in the bylaws, one of
whom shall be the chair;
    (2) 5 directors shall be public directors appointed by the Governor
with the advice and consent of the Senate;
    (3) 2 directors shall be public directors appointed by the Senate
President; and
    (4) 2 directors shall be public directors appointed by the Speaker
of the General Assembly.
    Upon the effective time of the conversion to a mutual holding
company system, the term of office of the public directors of the
reorganized insurer shall not immediately expire but rather be
temporarily continued with each such director continuing in holdover
status until such time as the appointing authority reappoints or renames
such director or appoints or names another director. The initial board
of directors of the mutual holding company shall be:
    (1) the elected directors of the reorganized insurer supplemented
by additional elected directors nominated and elected by the mutual
                                 10

holding company’s board after the effective time for a total number of
elected directors specified in the bill;
     (2) 5 public directors appointed by the Governor with the advice
and consent of the Senate;
     (3) 2 public directors named by the Senate President; and
     (4) 2 public directors named by the Speaker of the General
Assembly.
     The bill provides that each elected director shall have a term of
three years with up to two successive three-year terms following the
initial term for up to a total of three successive terms, and as provided
for in the bylaws, with such other term and term limits specifically
applying to the individual directors. The chief executive officer or
president of the mutual holding company shall be an elected director at
all times and shall not be subject to any term limit or election. Each
director shall meet the statutory and regulatory qualifications for the
mutual holding company system’s businesses and be free from
conflicts of interest that would prohibit the person from materially
executing the person’s duties as a director. Each public director shall
have a term of three years with up to two successive three-year terms
following the initial term, for a total of up to three successive terms.
Upon the effective time, the terms of office of the public directors of
the reorganized insurer shall continue until their respective successors
are appointed and qualified. No period during which a public director
holds over shall be deemed to be an extension of the public director’s
term of office for the purpose of determining the date on which a
successor’s term expires.
     The bill provides that there shall be a transitional period of 18
months following the effective time before elected directors of the
mutual holding company are subject to election by its members. The
first election shall occur at the first annual meeting following the
transitional period, and in accordance with the mutual holding
company’s bylaws.
     The bill provides that, to the extent practicable, the mutual holding
company is to make best efforts to reflect the racial, ethnic, and gender
diversity of the communities that it serves throughout the organization,
including the board of directors and executive leadership, to achieve
its mission.
     Upon the formation of a mutual holding company, the total number
of full-time employees that were employed within a mutual holding
company system shall be maintained for a transition period of 36
months following that formation based on the full-time employee
count of the health service corporation as of September 30, 2019, with
certain exceptions.
     The employment requirements of the bill do not supersede the
terms of any collective bargaining agreement or require a mutual
holding company system to replace headcount lost due to various
causes.
                                11

    As amended and reported, this bill is identical to Assembly Bill
No. 5119, as amended and reported by the Assembly Financial
Institutions and Insurance Committee on December 14, 2020.

COMMITTEE AMENDMENTS:
    The committee amended the bill to:
    (1) provide that the provisions of current law that exempt health
service corporations from taxes other than taxes on real estate and
equipment and taxes on premiums continue to apply to a mutual
holding company if the mutual holding company continues to
participate in the New Jersey Individual Health Coverage Program or
the New Jersey Small Employer Health Benefits Program;
    (2) clarify that the provisions of the Insurance Holding Company
System Act (C.17:27A-1 et seq.) apply to the reorganized insurer;
    (3) add the merger or consolidation of two or more companies to
the means by which the subsidiaries of a mutual holding company
system may be formed;
    (4) require the mutual holding company to ensure that any
ownership interest in a subsidiary be held by the mutual holding
company and any profits generated by that interest be returned to the
mutual holding company;
    (5) provide that, upon submission of an application to the
commissioner, a health service corporation must provide a copy of the
application to the Attorney General;
    (6) provide that the commissioner is to hold three public hearings
on the plan to form a mutual holding company within 90 days after the
commissioner determines that the filing is complete, with notice
provided by publication in a manner satisfactory to the commissioner;
    (7) provide that the commissioner is to approve of a plan of
mutualization and organization unless the commissioner finds the plan,
among certain other requirements, does not benefit the interests of the
policyholders of the health service corporation or treats them
inequitably;
    (8) permit the commissioner to engage the services of a consultant
to conduct a health impact study of the effects of the reorganization on
the health of the policy holders of the health service corporation and
the general public;
    (9) provide that if a written study or other expert report is
prepared, it shall be made available to the health service corporation
applying for reorganization, within a reasonable period of time prior to
the initial public hearing;
    (10) provide that commissioner shall possess supervisory powers
with respect to the insurance holding company system which shall
include the authority to monitor the mutual holding company systems
financial health, enterprise risk, and exam its operations pursuant to
P.L. 1970, c.22 (C.17:27A-1 et seq.);
                                 12

    (11) require the mutual holding company and its non-insurance
and insurance company subsidiaries to continue to operate a diverse
supplier program that promotes and invests in the utilization of
minority-owned and women-owned businesses in the procurement of
goods and services, including professional services;
    (12) provide that the application submitted pursuant to the bill be
a public record, except for certain confidential documents;
    (13) provide that the commissioner is to determine that the mutual
holding company’s system-wide health risk-based capital authorized
control level would fall below 550 percent before the deferment of the
annual assessment for a given calendar year;
    (14) extend the date beyond which the assessment years may not
be extended to 25 years from the effective time from 20 years from the
effective time;
    (15) provide that, to the extent practicable, the mutual holding
company is to make best efforts to reflect the racial, ethnic, and gender
diversity of the communities that it serves throughout the organization,
including the board of directors and executive leadership, to achieve
its mission;
    (16) make certain changes for federal tax filing purposes;
    (17) extend certain employment protection provisions for a period
of 36 months following the formation of the mutual holding company
from 24 months following the formation of the mutual holding
company; and
    (18) make certain changes concerning the appointment of public
directors.


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