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Before The Pennsylvania Insurance Department Re: Reserve and Surplus Levels of Hospital Plan and Professional Health Services Plan Corporations

Thirteen Pennsylvania groups are filing these Comments with attached Report of consultant Lawrence Kirsch and IMR Health Economics, LLC, with the Pennsylvania Insurance Department in response to the applications of the state’s four Blue Cross Plans to approve reserve and surplus levels. These are non-profit organizations and unions committed to improving the health of all Pennsylvanians and reducing mortality and morbidity in the Commonwealth by insuring access to needed healthcare and affordable health insurance for the well over one million Pennsylvania residents who are currently uninsured or underinsured.

These public interest organizations share a common interest in utilizing the considerable excess surplus of the four Blue Cross Plans across the Commonwealth to provide health insurance for the uninsured and related goals. They also believe that the Pennsylvania Insurance Department has an as yet unmet responsibility to specifically define and enforce the legally mandated charitable mission of the Blue Cross Plans and apply such policy in this proceeding by having excess surplus directed to these charitable purposes.