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petitioner’s and Group’s health plans in order to offer potential
enrollees a range of health services and pricing options. Health
Plans provided general and administrative services to petitioner
and Group including marketing, sales, enrollment, customer
service, claims processing, underwriting and actuarial
services, provider relations and contracting, management
information systems, and general accounting services.
Petitioner operated as an open panel, direct contract model
HMO offering health plans known as IHC Care and IHC Senior Care.
In short, as petitioner did not itself provide health care
services, it arranged for its enrollees to receive such services
by contracting directly with individual physicians (rather than a
physician medical group) to provide health services to its
enrollees.
A. IHC Care Health Plan
Petitioner offered its IHC Care health plan solely to
employers with more than 100 employees.6 Petitioner collected
premiums from its enrollees and arranged for them to receive
comprehensive health care services, including preventive care,
outpatient services, inpatient hospital services, emergency
6 Health Plans also offered a plan known as IHC Care. The
principal differences between petitioner’s IHC Care plan and the
IHC Care plan offered by Health Plans related to the methodology
applied in determining premiums and the enrollees’ degree of
access to primary care physicians. See IHC Health Plans, Inc. v.
Commissioner, T.C. Memo. 2001-246.
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Last modified: May 25, 2011