IHC Group, Inc. - Page 16




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          variety of health care services at no additional charge.                    
          Petitioner’s Core Wellness Program included annual worksite                 
          health screenings, group health risk profiles, a 24-hour nurse              
          hotline, ergonomics assessment and consulting, worksite health              
          seminars, and a health newsletter.  Petitioner did not offer its            
          Core Wellness Program to the general public.                                
          B.  Petitioner’s IHC Senior Care Health Plan                                
               Between 1993 and 1998, petitioner offered a Medicare “cost”            
          health plan known as IHC Senior Care (Senior Care plan).  Between           
          1996 and 1998, Care offered a Medicare “risk” health plan of the            
          same name.  Under petitioner’s Senior Care plan, Medicare                   
          eligible enrollees who paid the required premium were entitled to           
          obtain physician services (and a number of additional services              
          not covered by Medicare) from petitioner’s panel of primary care            
          physicians and specialists and were relieved of the obligation to           
          pay any deductible or co-insurance payments under Medicare Part B           
          (physician services).  Enrollees in petitioner’s Senior Care plan           
          retained their eligibility for Medicare Part A (hospital                    
          services) and continued to pay Medicare Part A premiums to the              
          Government.9                                                                



          9    Under Care’s Senior Care plan, Medicare eligible enrollees             
          agreed to obtain their Medicare Part A (hospital services) and              
          Medicare Part B (physician services) from Care’s network of                 
          providers and Care was compensated by the Government for each               
          enrollee on a prepaid, capitation basis.                                    





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