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> Document 649 : INS 99-14 : Hearing Decision
STATE OF MAINE
In gathering documents responsive to the Maine Medical Association’s ("MMA") motion to compel, Applicant Anthem Insurance Companies, Inc., on behalf of its subsidiary to be formed, Anthem Health Plans of Maine, Inc., d/b/a Anthem Blue Cross and Blue Shield (collectively "Anthem"), has identified documents that warrant confidential treatment and has submitted those materials to the Superintendent labeled as such. Pursuant to the October 19, 1999 Protective Order, Anthem submits the following memorandum in support of such treatment. Anthem requests confidential treatment for the referenced documents because they reflect Anthem’s internal business plans for the integration of the Anthem East data centers as well as the financial projections for the integrated system. Other responsive documents reflect position statements on Anthem East uniform medical policy that were developed by Anthem’s internal Medical Policy Team. Public disclosure of this information would benefit competitors and harm Anthem. Specifically, after reviewing the documents responsive to the MMA’s motion, Anthem hereby requests that the following document should be designated confidential and disclosed only in the manner set forth below: Document Numbers Category/Description Access
Anthem has, on prior occasions, submitted memoranda in support of confidential treatment that set forth the law generally applicable to confidential treatment of information under the Maine Civil Rules of Procedure and developed in Maine’s caselaw. (See, e .g., Memoranda in Support of Confidential Treatment of (1) Anthem’s Response to Superintendent’s Second Discovery Request, and (2) Supplement to the Form A.) To avoid repetition, Anthem incorporates these memoranda by reference. The Superintendent has determined, on prior occasions, that Anthem’s internal business plans and financial projections are confidential that that public disclosure would be harmful to Anthem and benefit competitors. The documents reflecting Anthem’s most recent plans for the integration of the Anthem East data centers fall into that same category and warrant confidential treatment. The policy statements developed for the East Region similarly are inappropriate for public disclosure. They reflect Anthem’s internal business practices and strategies. As such, the documents are competitively sensitive, and would be harmful to Anthem if publicly disclosed. For these reasons, Anthem respectively requests that the Superintendent designate the above-referenced materials as confidential, subject to disclosure only under the terms outlined above and exempt from disclosure under the FOAA.
DATED: March 28, 2000 ___________________________ James B. Zimpritch, Esq. Jeffrey M. White, Esq. Catherine R. Connors, Esq. Attorneys for Anthem Insurance Companies, Inc. PIERCE ATWOOD One Monument Square Portland, ME 04101 (207) 791-1100 CERTIFICATE OF SERVICE The undersigned hereby certifies that on March 28, 2000, a copy of Anthem’s Memorandum in Support of Confidential Treatment for Documents Responsive to the MMA’s Motion to Compel was served by electronic mail or via hand delivery on each of the persons listed below. Robert S. Frank, Esq. Harvey & Frank Two City center P.O. Box 126 Portland, Maine 04112 e-mail: frank@harveyfrank.com (Blue Cross/Blue Shield of Maine) Judith Chamberlain, Esq. State of Maine Department of the Attorney General 6 State House Station Augusta, Maine 04333-0006 e-mail: judy.chamberlain@state.me.us (Bureau of Insurance) William H. Laubenstein, Esq. State of Maine Department of the Attorney General 6 State House Station Augusta, Maine 04333-0006 e-mail: bill.laubenstein@state.me.us (Office of the Attorney General) Joseph P. Ditre, Esq. Consumer Health Law Program One Weston Court, Level One P.O. Box 2490 Augusta, Maine 04338-2490 e-mail: jditre@mainecahc.org (Consumers for Affordable Health Care Foundation/Coalition) Michele M. Garvin, Esq. Ropes & Gray One International Place Boston, Massachusetts 02110-2624 e-mail: Mgarvin@Ropesgray.com (Central Maine Healthcare Corporation; Central Maine Partners Health Plan) Bonnie Post Executive Director of the Maine Ambulatory Care Coalition P.O. Box 390 Manchester, Maine 04351 e-mail: bdpmacc@mint.net (Sacopee Valley Health center, Regional Medical center at Lubec, Eastport Health Care, Inc., and the Maine Ambulatory Care Coalition) John Dieffenbacher-Krall Executive Director Maine People’s Alliance 192 State Street Portland, Maine 04101 e-mail: MPA@gwi.net (Maine People’s Alliance) Gordon H. Smith, Esq. Maine Medical Association 30 Association Drive P.O. Box 190 Manchester, Maine 04351 e-mail: gsmith@ctel.net (Thomas D. Hayward, M.D., Maroulla S. Gleaton, M.D., And the Maine Medical Association)
Donald E. Quigley, Esq. General Counsel 465 Congress Street, Suite 600 Portland, Maine 04101-3537 e-mail: quigld@mail.mmc.org (Maine Medical center) Sandra L. Parker, Esq. John Doyle, Jr., Esq. Attorneys for MHA, Inc. 150 Capitol Street Augusta, Maine 04330 e-mail: sparker@themha.org jdoyle@preti.com (MHA, Inc.) Kellie P. Miller, M.S. Executive Director Maine Osteopathic Association 693 Western Avenue Manchester, Maine 04351 e-mail: meosteo@mint.net (Maine Osteopathic Association)
DATED: March 28, 2000 _____________________________ James B. Zimpritch, Esq. Jeffrey M. White, Esq. Catherine R. Connors, Esq. PIERCE ATWOOD Portland, Maine 04101 (207) 791-1100 Attorneys for Anthem Insurance Companies, Inc.
Last Updated: February 10, 2012 |
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