For Professionals: Advocacy & Policy
California Low-Income Health Advocate Alert On Medicare Part D
January 18, 2007
PLEASE DISTRIBUTE
More information on Medicare Part D, including past Alerts, can be found at cahealthadvocates.org/cmc/ website, and www.nsclc.org/areas/medicare-part-d
State Update
California Emergency Drug Benefit Expires on January 31, 2007
The Emergency Drug Benefit program, California’s backup system for dual eligibles having trouble accessing medically necessary medications under Medicare Part D, will end on January 31, 2007 unless immediate action is taken by the legislature and the Governor. Under the program, Medi-Cal provides emergency coverage of medications in those situation in which the Center for Medicare and Medicaid Services’ (CMS) computer systems are not working properly, the Part D plan charges the wrong co-pay amount or the Part D plan has not processed timely a physician’s exception or prior authorization request. Without this important safety net in place, dual eligibles who continue to have problems at the pharmacy counter may be sent home empty handed.
Saving this important benefit will require emergency action by the legislature and the Governor. In order for such emergency action to be taken, the legislature and the Governor must hear the stories of beneficiaries who continue to struggle with Part D and face barriers to accessing medically necessary medications. Please share your stories with California Health Advocates and/or the National Senior Citizens Law Center ( or ).
The California Department of Human Services has released a new bulletin announcing the pending termination of the Emergency Drug Benefit program. The bulletin also provides pharmacists with contact information for each of the Part D plans in California that have been eligible for the auto-assignment of dual eligibles. The bulletin is available at, http://files.medi-cal.ca.gov/….
Problems for “Undeemed” Beneficiaries
Advocates report that they are receiving calls from more and more individuals who had the Low Income Subsidy (LIS) in 2006, but have not been redeemed eligible for the subsidy in 2007. These individuals are subject to unsubsidized premiums, deductible and co-payments which are significantly higher than the amounts they were responsible for in 2006.
In California there were over 85,000 beneficiaries who were deemed eligible for the subsidy in 2006 who, as of September 2006, had not been redeemed for 2007. Many of these individuals are just becoming aware of the fact that they lost their LIS. While CMS was supposed to have mailed notices to these individuals informing them of their loss of subsidy back in September, most individuals that advocates have spoken with have no recollection of receiving a notice. Therefore, these individuals are learning that they have lost the subsidy the first time they try to pick up medications in the new year.
Individuals who now realize that they are no longer receiving the subsidy can still take action to become eligible again. A beneficiary can become eligible for the LIS by either 1) becoming eligible for Medi-Cal (including a Medicare Savings Program) or 2) applying for the LIS at a local Social Security Administration or Medi-Cal office. Many of those who lost their LIS benefits are “medically needy” individuals with a share of cost (SOC). If a beneficiary meets his or her SOC in any month in 2007, the beneficiary will be deemed eligible for LIS from the first day of the month in which the SOC is met until the end of 2007. Individuals entitled to Medicare based upon disabilities who cannot meet their SOC should consider whether they can qualify for Medi-Cal under the 250% working disabled program. For individuals who apply for LIS and are approved, their LIS eligibility will be retroactive to the month they filed their application.
While an individual is attempting to re-qualify for the LIS, there may be some relief available from their Part D plan. CMS has granted plans the authority to offer a grace period during the early months of 2007 to members who were not “re-deemed” automatically eligible for the LIS. Many of the larger, national Part D plan sponsors will be offering such a grace period. Per the grace period, these beneficiaries can continue to receive the subsidy while trying to re-qualify for the LIS. At least one plan, AARP Medicare Rx Plan Saver, will apply this grace period to all continuing members who were not redeemed. Other plans will require that the beneficiaries ask for the grace period and indicate that they have recently applied to become eligible for the LIS in 2007. CMS has indicated that plans can offer the grace period for up to 3 months. Plans are permitted to recoup unpaid premiums and cost sharing from members who do not become eligible for the LIS by the end of the grace period. Members who rely on prescription drug costs to meet their share of cost may not want to take advantage of the grace period as it will lower their costs.
The decision by AARP, and potentially other plans, to automatically apply the grace period may be harmful for those enrollees who do not yet realize that they have not been redeemed eligible for the subsidy. If they automatically receive the grace period, they may not learn that they have lost the subsidy until the grace period ends. By that time, they may be liable for costs incurred during the grace period and may no longer be able to utilize the Special Enrollment Period described below to change plans.
Individuals who had the subsidy in 2006, but are not receiving the subsidy in 2007 have a Special Enrollment Period (SEP) allowing one enrollment election between January 1 and March 31, 2007. See the Federal Update section below for more information on other important Special Enrollment Periods.
For more detailed information about redeeming and redetermination, see NSCLC’s guide for advocates, “The Low Income Subsidy: Redetermination and Redeeming,” available online at http://www.nsclc.org/….
Beware of PFFS Plans Being Marketed to Dual Eligibles
While some Medicare Advantage (MA) plans such as Special Needs Plans (SNPs) may be specially designed to coordinate care for dual eligibles, over the last several months advocates have heard from many dual eligible clients who report that insurance agents are aggressively marketing Private Fee-for-Service (PFFS) plans to them. PFFS plans allow enrollees to see any provider as long as the provider accepts the plan’s terms and conditions – a crucial point that is not being adequately explained (or understood) by many agents and brokers selling these plans. Instead, many prospective enrollees are being told that they can see any provider they like, and some dual eligibles are being told that they no longer need their Medicare and Medi-Cal cards. Early experience with PFFS plans in California in 2006, however, has shown that a number of providers are unwilling to see patients enrolled in PFFS plans, which means that if a dual eligible in the original Medicare program enrolls in a PFFS plan, s/he may no longer be able to see their regular providers.
Some PFFS plans advertise that state Medicaid programs will pay for dual eligibles' cost-sharing when they are enrolled in such plans. Despite these assertions by plans, however, the Medi-Cal program does not generally pay the Medicare Parts A and B cost-sharing for dual eligibles enrolled in MA plans (although it is DHS’ policy that providers who accept both Medicare and Medi-Cal cannot bill duals for this cost-sharing; see, generally, Medi-Cal Services Provider Manual, Part I – Medi-Cal Program and Eligibility, Medicare/Medi-Cal Crossover Claims at: http://files.medi-cal.ca.gov/…). In addition, some PFFS plans tout the “extra benefits” not covered by Medicare that duals can get from these plans such as vision, hearing and dental care, even though dual eligibles may already be entitled to these benefits through Medi-Cal.
In between Medicare enrollment periods last year, dual eligibles were targeted because they were some of the only individuals who could change plans mid-year, due to their ongoing SEP right (see below). This targeting of duals, however, appears to have continued unabated, even during enrollment periods open to all Medicare beneficiaries. HICAPs and other advocates are reporting that they are hearing from dual eligibles that have been "cold called" and visited by agents selling PFFS plans, sometimes through unsolicited door-to-door visits, which are clearly prohibited under Medicare’s otherwise lax marketing rules. It appears that some insurance companies are using their lists of current PDP enrollees (including dual eligibles who were assigned to benchmark plans) as “lead lists” for agents trying to sell the same sponsor’s MA products.
If you encounter instances of potential marketing misconduct, we suggest that you report the case to CMS; for further information, and to share stories of potential marketing misconduct, please contact David Lipschutz at California Health Advocates. Next week, California Health Advocates and Medicare Rights Center will be releasing an issue brief that discusses the marketing of Part D and MA plans (check California Health Advocates' website at www.cahealthadvocates.org/advocacy).
Sign Up This Quarter for Medicare Part A and QMB
Remember that January 1 through March 31, 2007 is the general enrollment period for the Medicare Program. In California, this is the key open window for certain clients to apply for Medicare Part A and benefits under the Qualified Medicare Beneficiary (QMB) program.
QMB provides beneficiaries with assistance in paying Medicare premiums, deductibles and co-insurance. QMB beneficiaries also automatically qualify for Medicare Part D’s Low Income Subsidy. QMB is most important for eligible seniors who do not already receive free Medicare Part A (this includes those without 40 quarters of covered work history, including many low-income senior immigrants).
To be eligible for QMB, an individual must be eligible for Medicare and have countable resources that do not exceed twice the maximum amount established for SSI eligibility and countable income that does not exceed 100 percent of the federal poverty guidelines. The current income eligibility limit for QMBs is $837 per month for an individual and $1120 per month for a couple. (This includes a universal $20 income disregard; additional disregards are allowed for earned income.) These monthly eligibility limits are expected to increase after revised 2007 federal poverty guidelines are issued. Countable resource limits are $4,000 for an individual and $6,000 for a couple. Certain income and resources, including some earned income, primary residence and personal possessions, are not counted in these calculations.
For more detailed information, see NSCLC’s online article at http://www.nsclc.org/….
Those who appear to be eligible as Qualified Medicare Beneficiaries but cannot afford to pay Part A premiums may enroll in Part A contingent on acceptance to that MSP program. See Social Security Administration, Program Operations Manual System (POMS) § HI 00801.140(D)(2), available online at https://s044a90.ssa.gov/….
For more information about conditional enrollment for QMB applicants, see the Center for Medicare Advocacy’s Fact Sheet, “January Begins Limited Opportunity to Expand QMB Coverage in Certain States,” http://www.medicareadvocacy.org/….
Federal Update
2007 Late Enrollment Penalty Waived for Low Income Subsidy Eligible Individuals
On January 8, 2007, CMS announced that there will be no Late Enrollment Penalty in 2007 for individuals eligible for the Low Income Subsidy. The Late Enrollment Penalty would normally be applied to any individual who failed to sign up for Medicare Part D during their initial enrollment period, went without creditable coverage for a period of 63 days and subsequently signed up for Medicare Part D. The decision not to apply the penalty to LIS beneficiaries means that individuals who are found eligible for the subsidy and sign up for a Part D plan by December 31, 2007 will never face a Late Enrollment Penalty, even if they could have signed up for a plan much earlier.
The Late Enrollment Penalty was also not applied to LIS beneficiaries who enrolled late in 2006.
Update on Enrollment Periods
Limited Special Enrollment Period (SEP) for Certain PDP Enrollees Who Did Not Receive an Annual Notice of Change (ANOC) from their Plan before November 15, 2006
In a January 3, 2007 memo to all Part D sponsors and Medicare Advantage plans, CMS explains that it “has established an SEP for individuals in a small number of PDPs who received their Annual Notice of Change (ANOC) information from their 2006 plan after November 15, 2006. The SEP provides affected individuals with one enrollment opportunity from January 1, 2007 through February 14, 2007. Affected individuals will receive a letter from their 2006 plan describing the SEP. This letter has a special code in the top right-hand corner, so that beneficiaries can easily reference the letter when contacting plans or 1-800-Medicare for assistance. This code is: SEP-A06. A copy of the memo is available at, http://www.nsclc.org/….
According to CMS Region IX, this SEP will not apply to Medicare Advantage plan enrollees because they are already entitled to make certain plan changes during the Medicare Advantage Open Enrollment Period (OEP) which lasts from January 1st through March 31st (for more information about enrollment periods, see resources below). Although advocates report that some MA plan enrollees and other PDP enrollees received late (or no) ANOCs from their plans, this SEP is only available to members of certain plans that reported to CMS that they were late in mailing out these notices. Region IX has indicated that the following specific PDP sponsors mailed notice of an SEP right to affected beneficiaries between December 29 and January 4, informing them of this additional enrollment opportunity that runs from 1/1/07 through 2/14/07: Anthem (S5726, S5596); ElderHealth (S5822, S1566); HealthNet (S5678); Torchmark (S5580, S5755); and United (S5921, S8520, S5805).
Congress Creates a New Medicare Advantage Enrollment Period Favoring PFFS Plans
In December 2006, the outgoing Congress created a new Medicare Advantage related enrollment period for Medicare beneficiaries, buried in a larger spending bill. See Division B, Title II, §206 of the Tax Relief and Health Care Act of 2006 (HR 6111), signed into law December 20, 2006. This new enrollment period allows individuals in the original, fee-for-service Medicare program one opportunity during the year to enroll in a Medicare Advantage-only plan (meaning an MA plan without Part D coverage). Because of the rules surrounding whether an MA enrollee can seek outside Part D coverage depending upon the type of MA plan s/he is enrolled in, this new enrollment period appears to primarily benefit the sponsors of MA Private Fee-for-Service (PFFS) plans, allowing them to market to beneficiaries in original Medicare year round (see discussion of PFFS marketing aimed at dual eligibles above).
Reminder – SEP Rights for Duals and Other Low-Income Individuals
For a discussion of SEP rights for duals and other low-income individuals, see our last Issue Alert (12/5/06) at, http://www.cahealthadvocates.org/cmc. Remember that individuals who are full benefit dual eligibles (as well as QMBs, SLMBs and QIs Medicare Savings Program enrollees) have an ongoing SEP, allowing them to change plans on a monthly basis. In addition, other low-income subsidy enrollees have at least one opportunity to change plans during 2007.
See the CMS memo to Part D plans (11/22/06) that references LIS SEPs: http://www.cms.hhs.gov/…pdf; also see also CMS’ updated SEP chart (which includes the late ANOC SEP discussed above) at: http://www.cms.hhs.gov/…pdf In addition, a replay of the 12/14/06 California Health Advocates/Center for Health Care Rights webcast entitled “Medicare & Part D Enrollment Periods: Rules and Realities” is available at: http://www.cahealthadvocates.org/…. To view this webcast you must register by clicking on the link above, enter your name, email address and enter the password: medicare (all lower case); accompanying materials can be found at: http://www.cahealthadvocates.org/….
LIS: Best Available Data Policy
Throughout 2006, many Low Income Subsidy (LIS) recipients faced problems obtaining drugs at the correct subsidy level. When pharmacists’ computer queries to plans failed to show accurate LIS status, these beneficiaries were forced to choose between paying high out-of-pocket costs or leaving without needed medication. According to CMS’ tentative guidance, plans are supposed to continue to apply a “best available data” policy in 2007, allowing recipients who can document their LIS status to receive the subsidy immediately. Beneficiaries who are entitled to LIS in 2007 therefore should take all possible evidence of their eligibility (e.g., state Medicaid card, a letter from the state Medicaid agency or SSA showing LIS status) with them to the pharmacy in 2007.
Beneficiaries who rely on the “best available data” policy to get their subsidy applied, should also forward copies of the proof of their eligibility directly to the plan. Under a new policy, plans must confirm the LIS eligibility of enrollees who benefit from the “best available data” policy. Beneficiaries should be warned that if plans are unable to confirm LIS eligibility, CMS will require plans to recoup the amount of any subsidy the individual received.
CMS’ recent memo on “Reconciling CMS Low Income Subsidy (LIS) Status and ‘Best Available Data’ Policy for 2006 and 2007” (December 6, 2006) is available online at http://www.nsclc.org/….
Recap of Transition Supply Requirements for New and Existing Enrollees
As mentioned in last month’s alert, some Part D enrollees who encounter problems obtaining prescribed drugs at the pharmacy in early 2007 can obtain limited relief by requesting a transition drug supply.
New Enrollees. According to recent CMS guidance on transition supplies, Part D plans must provide one temporary 30 day supply of an ongoing medication (i.e. a medication the enrollee is getting refilled) to new enrollees anytime within the first 90 days of coverage under a new Part D plan. This supply must be provided even if the drug is not on the plan’s formulary, or is on the formulary but is subject to utilization management (prior authorization, step therapy, etc.).
Residents of long-term care facilities are entitled to extended transition help. In addition to an initial 31 day supply of an ongoing prescribed medicine, plans must honor multiple fills for non-formulary drugs or drugs subject to utilization management rules during the first 90 days of transition.
LIS beneficiaries in California who were reassigned to a plan within the same plan sponsor because their 2006 plan premiums rose more than $2 above the 2007 benchmark have additional protections. In most cases, coverage for drugs they were taking in 2006 has been grandfathered into 2007 even if their 2007 plan would not normally cover the drug. Beneficiaries who were reassigned within the same plan sponsor and are having problems accessing medications they were taking in 2006 should request information about grandfathering and member continuity policies.
Existing Enrollees. For existing or current enrollees who are negatively affected by a change in plan formulary in 2007 (their medication has either been removed from the formulary or is subject to new utilization management requirements), CMS encouraged plans to provide some sort of transition process or exception review before January. If that process was not complete by the start of the new year, however, continuing enrollees should receive the same 30 day transition supply as new enrollees.
Special transition rules apply to enrollees who stay in the same plan in 2007 and were receiving medications in 2006 as a result of an exception. For these medications, plans have the option of continuing to “honor” the exception in 2007. If they decide that they will not honor the exception in 2007, they must provide written notice of this decision to the beneficiary. Notice can be provided in either of two ways: 1) within the original notice granting the exception (e.g. “this exception will expire on December 31, 2006”) or 2) in a separate notice delivered to the beneficiary at least 60 days before the end of the plan year. According to a memo to plans regarding transition policies and dated November 1, 2006, when a plan will not honor the exception it must also either 1) offer to process, near the end of 2006, a prospective exception request for 2007 or 2) provide a temporary supply of the requested drug at the beginning of 2007. If a temporary supply is provided, the plan must also provide a notice indicating that the beneficiary must either switch to an alternative, formulary medication or get an exception to continue receiving the requested drug.
Beneficiaries who receive a transition supply should immediately take steps to provide for the future. Often, plans do not explain the temporary nature of the fill and or how to ensure continued drug access. We suggest that beneficiaries contact their physician to determine whether there is an alternative medication on the plan’s 2007 formulary that can effectively serve the patient’s medical needs. If not, beneficiaries should work with their physician to file for an exception to get the drug covered. Beneficiaries may also consider switching plans if they have the right to do so (see “Update on Enrollment Periods” above).
CMS’ recent memo provides a detailed explanation of the transition policies that apply to particular beneficiary subgroups, and is available online at
http://www.nsclc.org/….
For more information about the mechanics of filing an exception to a Part D plan’s formulary or utilization management, see NSCLC’s “Medicare Part D Exceptions and Appeals: A Practical Guide,” available at http://www.nsclc.org/….
Advocacy Tips
Reminder: POS Codes for CVS and Walgreens
Advocates continue to report that pharmacies are unfamiliar with the Point of Sale/Service (also know as, POS or “Wellpoint”) system designed as a safety net for dual eligibles who show up as not enrolled in any Part D plan. This problem may be a result of differences in terminology. Below are the POS codes for two national chains.
- CVS/pharmacy (called condor codes) 23530 22560
- Walgreens (called Plan ID codes) DUALMPD FINDMPD
Filing an Appointment of Representation Form with CMS
Advocates who are interested in getting an appointment of representation form filed with CMS may want to try mailing a copy of the Appointment of Representative form, (certified mail) to "General Correspondence, Palmetto GBA. PO Box 100297, Columbia, SC 29202-3927." If the form is properly filed, you and the beneficiary you are representing will receive a notice acknowledging receipt of the form and stating that you have the authority to access the beneficiary’s Medicare records. The authorization should stay in place until the beneficiary asks that it be terminated.
Litigation Update
Situ Case Moves Forward, Nationwide Class Certified
A federal judge in San Francisco has ruled that the lawsuit, Situ v. Leavitt, filed on behalf dual eligible Medicare beneficiaries against the federal government for its failure to protect Medicaid beneficiaries in the Medicare prescription drug program, can proceed as a nationwide class action.
The Centers for Medicare & Medicaid Services (CMS), which is the responsible agency within the federal Department of Health and Human Services, contended that the court had no jurisdiction to hear the case and that the numerous problems cited by the plaintiffs were not attributable to the federal government, but, rather, to a particular private plan, a state, a pharmacist, or the plaintiffs themselves. In an order dated December 18, 2006, the Court rejected most of the government’s arguments, upholding the right of eight of the individual plaintiffs to proceed and to prove their claims.
In a separate decision (issued January 12, 2007), the judge certified the case as a nationwide class action. The Court rejected the government’s contention that class status should not be granted because the Plaintiffs had not named specific policies or procedures behind the problems experienced by program participants, noting that CMS’ failure to carry out the Medicare Part D program adequately is sufficient grounds for certifying the class action. The class is defined as all “full benefit dually eligible Medicare beneficiaries who have not received full benefits of Medicare Part D prescription drug coverage or the Low Income Subsidy program” because of poor plan enrollment management. Beneficiaries must have filed a claim with CMS, a plan or the state, complaining of enrollment difficulties to formally considered members of the class.
As mentioned in earlier alerts, NSCLC and the Center for Medicare Advocacy, Inc. (CMA) filed the lawsuit on April 26, 2006. The case raises the systematic failures of CMS’s computer system set up for Medicare Part D beneficiaries and its inadequate safety net for low income people struggling to navigate the system to obtain their drugs. In rejecting CMS’s attempts to avoid responsibility for system failures, the court noted that CMS is responsible for enrolling dual eligibles and must allow them to change plans. The court noted that CMS’ computer system, even when working correctly, can take up to 76 days to relay low income subsidy information to a pharmacist’s computer.
New CMS Materials
In early December, CMS released a Q&A on Part D and vaccines. The Q&A is available at http://www.ascp.com/…pdf.
CMS has released the final chapter of the Medicare Prescription Drug Manual: Chapter 14 – Coordination of Benefits. The document is available at http://www.cms.hhs.gov/…pdf.
On December 5, 2006, CMS released a memorandum addressing the relationship between Part D coverage and the FDA’s Less-than-effective Drug Efficacy Study Implementation (LTE DESI) drugs and Oral Anti-Cancer Agents covered by Part B. “Clarification of LTE DESI Drugs and Oral Anti-Cancer Agents” is available at http://www.dom.state.ms.us/…pdf.
Information for Advocates
Announcements from CHA
California Health Advocates is pleased to announce the following schedule of events:
- January 31 – “Resources for the Intelligent Rx Shopper” Tele-workshop -10:00 a.m. – 11:30 a.m.: Free tele-workshop introduces participants to the Consumer Reports Best Buy Drugs program.
- Schedule of California Medicare Coalition Meetings:
- February 14 – Statewide Telephone Meeting - 10:00 a.m. to Noon.
- April 4 – Meeting – Southern California (location to be announced)
- April 11 – Meeting – Northern California (location to be announced)
- Schedule of California Medicare Coalition Regional Forums –10:00 am - Noon
Topic: “Marketing of Rx Drug Plans in California”- March 6 – Bakersfield
- March 20 – Pacific Grove
- April 24 – Riverside
- May 8 – San Francisco
- June 13 – Redding
For more information on these upcoming events or to join the California Medicare Coalition please visit California Health Advocates' website: http://www.cahealthadvocates.org/cmc/ or email .
NSCLC Releases “An Advocate’s Guide to Solving Problems Under Part D”
The new guide provides advocacy tips for solving the most common problems faced by Medicare Part D beneficiaries, emphasizing, in particular, potential problems related to the transition to 2007. The tool is available at http://www.nsclc.org/….
NSCLC plans to update this guide with additional tips as we learn from advocates across the country what is working for them, so please share your tips and experience with us, call 510-663-1055: Jeanne Finberg, Directing Attorney, ext. 305, Katharine Hsiao, Staff Attorney, ext. 306, Kevin Prindiville, Project Attorney, ext. 307, Georgia Burke, Project Attorney, ext. 304, or Anna Rich, Liman Fellow, ext. 303 or email .
Other New Resources
There are additional resources available to advocates assisting beneficiaries with the transition to 2007.
The Center for Medicare Advocacy has prepared a summary of transition supply requirements, http://www.medicareadvocacy.org/….
Health Assistance Partnership has created a list of important information to share with pharmacists when beneficiaries face barriers to accessing their medications. http://www.hapnetwork.org/…
Keep Those Stories Coming
The adverse publicity regarding the problems that dual eligibles are facing is helping to get the changes we need at the state and federal levels. We need to keep our client stories in the press to get more permanent relief. Please help us by identifying clients or their family members who are willing and able to talk to the press, or willing to share their stories. We are particularly interested in hearing stories about language access, enrollment problems, and initial experiences with the 2007 plans. Send stories and contacts to , .
More information about Medicare Part D is posted on the NSCLC website at www.nsclc.org/areas/medicare-part-d. We will continually post new training materials as this program develops. Other helpful websites:
- Center for Medicare Advocacy at www.medicareadvocacy.org
- Health Consumer Alliance at www.healthconsumer.org
- Families USA at www.familiesusa.org
- Medicare Rights Center at www.medicarerights.org
- California Health Advocates at www.cahealthadvocates.org
- California HealthCare Foundation at www.chcf.org/topics/healthinsurance/drugbenefit
- Health Assistance Partnership at www.healthassistancepartnership.org
- Kaiser Family Foundation at www.kff.org/medicare
For more information, e-mail California Health Advocates or NSCLC:
California Health Advocates
National Senior Citizens Law Center
Jeanne Finberg
Katharine Hsiao
Georgia Burke
Kevin Prindiville
Anna Rich
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This Alert is provided by California Health Advocates in partnership with National Senior Citizens Law Center with support from The California Endowment.
California Health Advocates: http://www.cahealthadvocates.org
National Senior Citizens Law Center: http://www.nsclc.org