Texas Register
(25 TexReg 10437). Sections 21.2803
and 21.2810 are adopted without changes and will not be republished.
These amendments are necessary to clarify and update the "clean claim"
rules that apply to claims filed for non-confinement services, treatments,
or supplies rendered on or after August 1, 2000, and to claims filed for services,
treatments, or supplies for in-patient confinements in a hospital or other
institution that began on or after August 1, 2000. The amendment to §21.2803(b)(1)(L)(ii)
is necessary to facilitate the electronic claims filing process and is in
response to petitions from numerous physicians and providers. The amendment
to §21.2809(b) is necessary to clarify the essential information that
is to be included in the notice of audit results and will assist physicians
and providers in more efficient and accurate recordkeeping of audited claims
as well as allow physicians and providers to suggest a refund method other
than a chargeback. Articles 3.70-3C §3A(e) and 20A.18B(e) of the Insurance
Code as enacted by House Bill 610 (Acts 1999, 76th Leg., ch. 1343, p. 4556,
eff. Sept. 1, 1999) require notice of the audit results to be provided to
the physician or provider and require a refund to be made to the preferred
provider carrier or HMO upon completion of the audit in the event of overpayment
to the physician or provider. The amendment to §21.2810 is necessary
to allow private metered postmarks to be an acceptable proof of postmark in
those instances when the claim payment is delivered by the U.S. Postal Service.
The amendment is in response to information received by the department from
the U.S. Postal Service that private metered mail is checked by the post office
to verify the correct date and is returned to the customer if incorrectly
dated.
In response to comments, changes have been made to the proposed amendments
to §21.2809(b) as published. For purposes of clarification, references
to "notification" have been changed to "written notification."
Section 21.2803(b)(1) specifies the elements necessary for the submission
of a clean claim by physicians and noninstitutional providers. The amendment
to §21.2803(b)(1)(L)(ii) specifies the requirements relating to the element
on disclosure of any other health care coverage when the response is "no."
Section §21.2809(b) specifies procedures for refunds due to the HMO or
preferred provider carrier upon completion of the audit. The amendment also
provides that existing or future contractual arrangements that allow alternative
reimbursement methods in the event of overpayment to the physician or provider
are not affected by the rule. Under the amendment to §21.2810, private
metered postmarks will be acceptable proof of postmark in those instances
when the claim payment is delivered by the U.S. Postal Service.
§21.2803(b)(1)(L)(ii) Essential data elements for physicians and noninstitutional
providers
Comment: Numerous commenters requested that proposed §21.2803(b)(1)(L)(ii)
be revised to remove the requirement that the physician or provider keep on
file a document signed within the past 12 months stating that there is no
other health care coverage. One commenter stated that the proposed amendment
will result in physician confusion as well as the potential for carriers to
intentionally or inadvertently circumvent the law. Three commenters stated
that the proposed amendment violates the intent of House Bill 610 to promulgate
rules that promote prompt payment. One commenter stated that the proposed
requirement gives health plans one more reason to deny or delay payment on
a claim. One commenter stated that it is unclear as to the department's legal
authority to place on physicians mandates that are separate from an "essential"
insurance requirement. Several commenters stated that the proposed requirement
will place additional burden and expense on the physician's office. Three
commenters stated that the proposed amendment shifts a major business function
of insurance onto the physicians because insurance companies are in the most
appropriate position to address coordination of benefit issues, which are
a function of the business of insurance; one of these commenters stated that
this will impede the delivery of health care. Five commenters stated that
the proposed amendment will have little or no effect on facilitating electronic
claims filing. One of these commenters stated that the inability to use electronic
submission of claims increases overhead expenses and delays payments. One
commenter stated that the proposed amendment is confusing in light of HIPAA
(Health Insurance Portability and Accountability Act of 1996), which promotes
electronic filing of claims, and that it violates federal mandates within
HIPAA because the proposed amendment continues to promote manual attachments.
Several commenters stated that HCFA (Health Care Financing Administration)
does not have this requirement, and that it is the responsibility of the payor
to seek coordination of benefits from the patient. The commenters stated that
the payor should accept the due diligence of the physician that answers "no"
in box 11d of a HCFA 1500 form and process the claim accordingly. One commenter
stated that these rules are based primarily on HCFA requirements. One commenter
stated that the department has not given adequate justification of the need
for this requirement. One commenter stated that many HMOs and preferred provider
carriers do not want the "no other health coverage" documentation as it would
be too burdensome. Several commenters stated that by requiring physicians
or providers to allow open access to the additional documentation is an unnecessary
compromise and further complicates the claims payment system.
Response: The department disagrees. Many of the comments seem to result
from a misunderstanding of how the amendment will function. It is the department's
understanding that, currently, most physicians and providers obtain or attempt
to obtain health care coverage information from their patients (i.e., enrollees/insureds)
as a standard business practice in order to submit claims to or to seek reimbursement
from the responsible parties: an insurer, an HMO, a self-funded plan, Medicaid,
Medicare, or the patient. This information is currently collected by physicians
and providers at various times and through various means: in an initial or
annual office visit questionnaire, in a sign-in sheet enrollees/insureds are
requested to complete at office visits, or upon obtaining certain services,
treatment or supplies from the physician or provider, or as part of the physician's
or provider's routine record updating. Under the amendment, physicians and
providers must retain in their files the form completed by the enrollee/insured
and provide this form to the HMO or preferred provider carrier upon request.
This form could be a copy of the initial or annual office visit questionnaire,
sign-in sheets, or other similar document signed by the enrollee/insured within
the last 12 months that there is no other health coverage. If the HMO or preferred
provider carrier has reason to see such documentation, such as the HMO or
preferred provider carrier having information that the enrollee/insured may
have other coverage, they may request the physician or provider to submit
a copy of the signed document. This request does not affect in any way the
45-day requirement under which the HMO or preferred provider carrier must
process a clean claim in accordance with §21.2807 or audit a clean claim
in accordance with §21.2809. Thus, an HMO or preferred provider carrier
may not delay the processing of a clean claim if the physician or provider
has responded "no" to the disclosure of health care coverage (HCFA 1500, field
11d), even if the carrier requests a copy of the signed document stating that
there is no other health care coverage. For these reasons, the department
disagrees that the amendment provides grounds for HMOs or preferred provider
carriers to intentionally or inadvertently circumvent the law, that the amendment
violates the intent of House Bill 610 to promote prompt payment, and that
the amendment gives HMOs or preferred provider carriers one more reason to
deny or delay payment on a clean claim. The amendment is a balanced and reasonable
approach to address the coordination of benefit issues that arise in the processing
of clean claims. The department disagrees that the amendment shifts a function
that belongs to preferred provider carriers or HMOs onto the physicians or
providers. Preferred provider carriers and HMOs that have coordination of
benefit provisions in their insurance policies or health care plans are responsible
for obtaining information if the patient has other health care coverage and
the information is necessary for determining which coverage is primary or
secondary pursuant to 28 TAC, Chapter 3, Subchapter V, and 28 TAC §11.511(1).
The department believes that the adoption of the amendment is necessary to
implement Articles 3.70-3C and 20A.18B. Under the amendment, the data elements
relating to other health care coverage are not essential for a claim to be
"clean" when the response is "no" to the disclosure of any other health benefit
plans; therefore, it is necessary that HMOs and preferred provider carriers
be able to obtain reliable information from the physician and provider that
supports the "no" response. The rule does not specify when this information
can be requested, but the department expects that HMOs and preferred provider
carriers will have a good and valid reason to request the information. In
addition, it is the department's understanding that physicians and providers
routinely obtain information about other insurance in order to file claims
for payment of health care services, treatment, and supplies. Therefore, the
department disagrees that the amendment places additional burden and expense
on the physician or provider. Physicians and providers need the information
on other health care coverage to file claims properly and to receive proper
payment for the services and treatment that they have rendered. Because the
amendment is based on what the department understands to be the standard business
practice of physicians and providers who routinely file claims for payment
of health care services, treatment, and supplies, the department does not
believe that there is any reason for physician or provider confusion. The
department believes that the amendment will facilitate the filing of electronic
claims because claims can be submitted electronically without providing a
copy of a signed document stating that there is no other health care coverage;
the signed document need only be provided in those instances in which the
HMO or preferred provider carrier requests a copy of the document, and that
request will be made after the claim is submitted electronically. Therefore,
the amendment does not violate the HIPAA mandates on electronic claims and
does not result in any increase in overhead expenses or delay in payments
because of an inability to use electronic submission of claims. The department
disagrees that it is appropriate or necessary for the clean claims elements
to conform precisely to the HCFA requirements for Medicare claims with regard
to the other health care coverage requirements when the response is "no" because
Medicare is primary coverage for the majority of its claims, and thus coordination
of benefits is not as significant an issue. Moreover, a recent Government
Accounting Office report identified Medicare secondary payor debt as a major
source of overpayment by HCFA for Medicare services, so the department does
not believe that it is persuasive to rely upon Medicare practices as determinative
with regard to this issue. The department disagrees that it has not given
adequate justification of the need for the amendment; the rule proposal published
in the October 20, 2000 issue of the Texas Register (25 TexReg 10437) explained
that the amendment was being proposed to revise the requirements (adopted
as part of the "clean claim" rules (28 TAC §§21.2801-21.2816)) relating
to the element on disclosure of any other health care coverage when the response
is "no"; that the amendment is necessary to facilitate the electronic claims
filing process; and that the amendment was proposed in response to petitions
from physicians and providers. Those HMOs or preferred provider carriers that
do not want the "no other health coverage" documentation because it is too
burdensome do not have to request it; the requesting of the documentation
is optional for the HMO or preferred provider carrier. The department considers
it inappropriate for an HMO or preferred provider carrier to seek the documentation
indiscriminately, and the department will monitor complaints to identify any
abuses. The amendment does not require open access to documentation that does
not already exist for physicians and providers who routinely file claims for
payment of health care services, treatment, and supplies; HMOs and preferred
provider carriers routinely request physicians and providers to furnish this
and other information as part of the claims handling process.
Comment: Two commenters objected to the requirement that the physician
or provider keep on file a document signed within the past 12 months that
there is no other health care coverage because the 12-month requirement is
too long a period. The commenters stated that the document should be dated
close to the date of service because such information may become outdated
or incorrect in a shorter period of time. One commenter recommended requiring
that the document on file be signed within either the past 30 days or within
30 days of the date of service for the claim being submitted. The other commenter
recommended that the 12 months be reduced to six months as a balanced approach
that is more efficient and reasonable.
Response: The department disagrees. Because many physicians and providers
routinely obtain information from enrollees/insureds concerning coverage by
other health benefit plans more frequently than every 12 months, depending
upon the frequency of the visits (i.e., via sign-in sheets enrollees/insureds
complete at office visits or upon obtaining certain services, treatment or
supplies from the physician or provider or as part of the physician's or provider's
routine record updating which may be more often than every 12 months), in
many instances the physician or provider will have information that is provided
close to the date of service or treatment. The rule does not require the physician
or provider to follow-up with the patient/enrollee to determine the accuracy
of the patient/enrollee statement; it only requires the physician/provider
to provide a copy of the statement when requested. HMOs and preferred provider
carriers that have coordination of benefit provisions in their contracts may
request this information when they have information that the patient/enrollee
may have other health care coverage. These HMOs and preferred provider carriers
are responsible pursuant to coordination of benefit requirements (28 TAC,
Chapter 3, Subchapter V, and 28 TAC §11.511(1)) to determine (a) if there
was or was not actual coverage by other health benefit plans at the time the
service or treatment was rendered and (b) if there was, determine what plan
is primary and what plan is secondary.
Comment: One commenter recommended that the amendment be applicable only
to electronically submitted claims and not to paper claims; the commenter
stated that for paper claims there seems to be no reason not to attach the
form.
Response: The department disagrees. To promote uniformity and to streamline
the claims filing process, the department believes that paper claims and electronically
filed claims should have the same requirements. Furthermore, the ability of
an HMO or preferred provider carrier to request the documentation should not
be abused by seeking the documentation in all instances or indiscriminately.
Comment: One commenter requested that a group of people familiar with the
actual process of claims filing be included in the process for determining
the requirements for clean claims. According to the commenter, each of the
insurance companies have somewhat different requirements for clean claims
but all avoid the 45 day payment requirement by requiring the physician to
offer documentation that the patient has no other insurance as primary.
Response: The department appreciates the suggestion, and, in fact, the
clean claims elements were developed with significant input from individuals
directly involved in the claims payment process, including representatives
of HMOs, preferred provider carriers, hospitals, physicians, and other providers.
In addition, the department has made every attempt to ensure that the clean
claims rules: properly implement House Bill 610; fairly balance the interest
of all affected parties; and do not unduly burden any person or entity affected
by the rules. Under the amendment, upon receipt of a clean claim for which
the physician or provider has responded "no" to the disclosure of other health
care coverage (HCFA 1500, field 11d), HMOs and preferred provider carriers
must process the clean claim in accordance with §21.2807 or audit the
clean claim in accordance with §21.2809. HMOs and preferred provider
carriers may not delay the processing of such clean claims even if the HMO
or preferred provider carrier requests from the physician or provider a copy
of the signed document stating that there is no other health care coverage.
§21.2809(b) Audit Procedures
Comment: Numerous commenters requested that the proposed amendment to §21.2809(b)
be revised to require that the notification be "written" and to provide that
the HMO or preferred provider carrier may not make a chargeback sooner than
the 45th day after notice unless the physician or provider contacts the HMO
or preferred provider carrier to arrange for reimbursement through an alternative
method.
Response: The department agrees in part and disagrees in part. For purposes
of clarification, the proposed amendment to §21.2809(b) is revised to
change "notification" to "written notification." The commenter's recommendation
that the HMO or preferred provider carrier may not make a chargeback sooner
than the 45th day after notice unless the physician or provider contacts the
HMO or preferred provider carrier to arrange for reimbursement through an
alternative method is inconsistent with House Bill 610. Articles 3.70-3C, §3A(e)
and 20A.18B(e) of the Insurance Code, as enacted by House Bill 610, provide
that following completion of the audit, any additional payment due a physician
or provider or any refund due the HMO or preferred provider carrier is to
be made not later than the 30th day after the later of the date that the physician
or provider receives notice of audit results or, if an appeal was filed before
expiration of the 30-calendar-day refund period, any appeal rights of the
insured or enrollee are exhausted.
Comment: One commenter recommended that the notification required in §21.2809(b)
identify the relevant patient's name, the applicable date(s) of service(s),
and on a service by service basis, either the additional percentage payment
or the chargeback percentages as they affect the amounts already paid as determined
by the results of the audit. The commenter stated that this change is needed
to add more specificity to the chargeback notification and thus enhance the
purpose behind the amendment.
Response: The department disagrees. The intent of the amendment is not
to specify every single piece of information that must be included in the
notice of audit results but rather to clarify the essential information that
is to be included in the notice of audit results in the event that the HMO
or preferred provider carrier intends to make a chargeback and to allow flexibility
to HMOs and preferred provider carriers as to other information to be included
in the notice of audit results. Additionally, to require the requested information
in the notice of audit results could arguably impose requirements on HMOs
and preferred provider carriers and other affected parties for which they
have not received notice and an opportunity to comment. Therefore, the imposition
of these additional requirements could be considered a substantive change
in the proposed rule which would require republication of the amendment with
another 30-day comment period before the rule could be considered for adoption.
Comment: One commenter recommended that the proposed language "unless otherwise
agreed to by contract" in §21.2809(b) be deleted. According to the commenter,
this is recommended because of the recognized disparity (as evidenced by the
passage of SB 1468 relating to joint negotiations by physicians) in contractual
bargaining power between the great majority of physicians and insurance companies
that allow the clean claim rules to be circumvented by contract and thereby
result in the deterioration or elimination of the intended purpose of the
rule.
Response: The department disagrees. Articles 3.70-3C, §3A and 20A.18B
recognize the right of physicians and providers and HMOs and preferred provider
carriers to contract. Therefore, it is necessary to include the language "Unless
otherwise agreed to by contract" because the physician or provider and the
HMO or preferred provider carrier have the ability to agree to chargeback
procedures by contract. If the parties do otherwise agree, there may not be
a need for the HMO or preferred provider carrier to include the required statement
in the notification of audit results.
Comment: One commenter recommended that the proposed amendment to §21.2809(b)
be revised to remove the ability of the provider to "contact" the HMO or preferred
provider carrier to arrange for an alternative reimbursement method and instead
to provide that the HMO or preferred provider carrier will make a chargeback
unless the HMO or preferred provider carrier agrees to accept reimbursement
through an alternative method. The commenter stated that while they do not
think that this language is intended to permit a physician or provider to
deprive an HMO or preferred provider carrier of its right to make a chargeback
merely by contacting the HMO or preferred provider carrier it would be easy
to construe the proposed language as having that effect. The commenter believes
that it is necessary that the HMO or preferred provider carrier "agrees" to
such an alternative reimbursement method and that much more than a mere "contact"
is necessary.
Response: The department disagrees with the requested change. The department
agrees that the proper reading of the amendment is that the HMO or preferred
provider carrier must agree to accept reimbursement through an alternative
method, but the department interprets the language "arrange for reimbursement
through an alternative method" to mean that there must be mutual agreement
as to the method of reimbursement. Therefore, the department does not believe
that any change is necessary because the rule as proposed contemplates agreement
between the physician or provider and the HMO or preferred provider carrier.
Comment: One commenter recommended deletion of the proposed change to §21.2809(b).
The commenter stated that the proposed change does not appear to be justified
by practice or by House Bill 610. According to the commenter, neither House
Bill 610 nor the rules define "alternative methods" and there is no explanation
in the proposed rule changes for the new requirements.
Response: The department disagrees. It is the department's understanding,
based on information received from physicians, providers, HMOs and preferred
provider carriers and groups representing these parties, that it is an existing
business practice for HMOs and preferred provider carriers to make chargebacks
to recoup any overpayment to physicians and providers. While House Bill 610
does not specifically address "chargebacks," Articles 3.70-3C §3A(e)
and 20A.18B(e) of the Insurance Code, as enacted by House Bill 610, require
notice of the audit results to be provided to the physician or provider and
require a refund to be made to the preferred provider carrier or HMO upon
completion of the audit in the event of overpayment to the physician or provider.
"Alternative methods" of reimbursement could be any means, other than chargebacks,
by which the physician or provider may refund any overpayment to the HMO or
preferred provider carrier, including check, cash, or installment plan. As
explained in the rule proposal published in the October 20, 2000 issue of
the Texas Register (25 TexReg 10437), the amendment is necessary to clarify
the essential information that is to be included in the notice of audit results
if, upon completion of the audit, a refund is due from the physician or provider
and the HMO or preferred provider carrier intends to make a chargeback against
the physician or provider. Also, as explained in the published rule proposal,
the amendment is needed to assist physicians and providers in more efficient
and accurate recordkeeping of audited claims and is needed to clarify that
existing or future contractual arrangements that allow alternative reimbursement
methods in the event of overpayment to the physician or provider are not affected
by the rule. Additionally, the department received a petition from various
groups to amend the clean claims rules to "ameliorate the accounting difficulties
imposed on physicians and providers by chargeback arrangements. . . ." and
to ensure "that all parties have a mutual understanding of what occurs when
a claim has been incorrectly paid." The rule is similar to the amendment requested
by the petitioners.
Comment: Several commenters objected to HMOs and preferred provider carriers
being allowed to recover overpayments through chargebacks and recoupments.
One commenter stated that in many instances chargebacks are inaccurate. Two
commenters called chargebacks an "accounting nightmare." According to one
commenter, if an insurance company has overpaid a claim, they need only send
proper documentation of that payment, and a refund is issued in a timely manner.
Three commenters stated that chargebacks and recoupments are extremely burdensome
for physicians and that the regulations should allow flexibility regarding
payment so that physicians can decide how best to deal with this as long as
the repayment request is made within the appropriate time period and is justified.
One commenter stated that carriers should be held to a deadline when asking
for a payment back due to an error in processing. One commenter stated that
a process of recoupment that allows insurers to recover overpayments without
clearly relating the overpayment to an individual is unfair. According to
this commenter, the deduction usually requires a call to the insurance company
to determine where the money is being recouped from; the commenter recommended
the more accurate and preferred method of refund requests and stated that
physicians are willing to have reasonable time limits set for the refunds.
One commenter objected to chargebacks and recoupments which do not give the
physician's staff adequate time for research and response.
Response: Section 21.2809(b) recognizes that chargebacks are an existing
business practice and one possible method by which HMOs and preferred provider
carriers may recoup overpayment to physicians and providers; in some instances
chargebacks may be the most efficient means of handling an overpayment. Section
21.2809(b) recognizes the various payment systems of the different types of
physicians and providers and allows flexibility to both the physicians and
providers and HMOs or preferred provider carriers to develop the most effective
and efficient method of handling any overpayments. Neither the current rule
nor the amendment imposes chargebacks on HMOs or preferred provider carriers
or physicians or providers. The department does not have the authority under
House Bill 610 to require or prohibit chargebacks.
§21.2810 Date of Claim Payment
Comment: One commenter expressed support for the amendment as published,
and one commenter stated that the amendment posed no current concern.
Response: The department appreciates the commenters' support.
For with changes: Arlington Family Practice, Bent Tree Family Physicians,
Blue Cross/Blue Shield of Texas, Dallas County Medical Society, The Diaz Clinic,
Digestive Health Associates of Texas, Family Healthcare Center, Family Medicine
Associates of Texas, Garland Medical Clinic, The Health Group, Heart Place,
Jefferson Physician Group, Medical Clinic of North Texas, Orthopedic Associates
of Dallas, Orthopedic Specialty Associates, Teen Care of Irving, Texas Association
of Insurance Officials, Texas Medical Association, Texas Pulmonary Consultants,
Urology Clinics of North Texas, and 17 individual physicians.
Against: None.
The amendments are adopted under the Insurance Code Articles
3.70-3C and 20A.18B and §36.001. Articles 3.70-3C, §3A(a) and 20A.18B(a)
provide that under these sections, "clean claim" means a completed claim,
as determined under department rules, submitted by a physician or provider
for medical care or health care services under a health insurance policy or
health care plan. Articles 3.70-3C, §3A(e) and 20A.18B(e) provide that
following the completion of the audit of a clean claim, any additional payment
due a physician or provider or any refund due the preferred provider carrier
or HMO shall be made not later than the 30th day after the later of the date
that the physician or provider receives notice of the audit results or any
appeal rights of the insured are exhausted. Articles 3.70-3C, §3A(c)
and 20A.18B(c) specify actions that must be taken by an HMO or preferred provider
carrier within 45 days after the date of receipt of a clean claim, including
payment of the total amount of the claim in accordance with the contract between
the physician or provider and the HMO or preferred provider carrier. Articles
3.70-3C, §3A(n) and 20A.18B(o) authorize the Commissioner to adopt rules
as necessary to implement these articles. Section 36.001 provides that the
Commissioner of Insurance may adopt rules for the conduct and execution of
the powers and duties of the department only as authorized by statute.
§21.2809.Audit Procedures.
(a)
If an HMO or preferred provider carrier is unable to pay
or deny a clean claim, in whole or in part, within the statutory claims payment
period specified in §21.2802(25)(B) of this title (relating to Definitions),
the unpaid portion of the claim shall be classified as an audit, and the HMO
or preferred provider carrier shall pay 85% of the contracted rate on the
unpaid portion of the clean claim within the statutory claims payment period.
Payment of 85% of the contracted rate on the clean claim is not an admission
that the HMO or preferred provider carrier acknowledges liability on that
claim.
(b)
Upon completion of the audit, if the HMO or preferred provider
carrier determines that a refund is due from a physician or provider, such
refund shall be made within 30 calendar days of the later of written notification
to the physician or provider of the results of the audit or exhaustion of
any subscriber or patient appeal rights if a subscriber or patient appeal
is filed before the 30-calendar-day refund period has expired, and may be
made by any method, including chargeback against the physician or provider,
or agreements by contract. The written notification of the results of the
audit shall include a listing of the specific claims paid and not paid pursuant
to the audit, including specific claims and amounts for which a refund is
due. Unless otherwise agreed to by contract, if an HMO or preferred provider
carrier intends to make a chargeback, the written notification shall also
include a statement that the HMO or preferred provider carrier will make a
chargeback unless the physician or provider contacts the HMO or preferred
provider carrier to arrange for reimbursement through an alternative method.
Nothing in this provision shall invalidate or supersede existing or future
contractual arrangements that allow alternative reimbursement methods in the
event of overpayment to the physician or provider.
(c)
Upon completion of the audit, if the HMO or preferred provider
carrier determines that additional payment is due to the physician or provider,
such additional payment shall be within 30 calendar days after the completion
of the audit.
This agency hereby certifies that the adoption has been reviewed
by legal counsel and found to be a valid exercise of the agency's legal authority.
Filed with the Office of
the Secretary of State on January 25, 2001.
TRD-200100444
Lynda Nesenholtz
General Counsel and Chief Clerk
Texas Department of Insurance
Effective date: February 14, 2001
Proposal publication date: October 20, 2000
For further information, please call: (512) 463-6327