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               Petitioner compensated IHC Direct Care Plus PCPs and SCPs on           
          a discounted fee-for-service basis.  During 1999, petitioner                
          applied discounts of 26 percent and 38 percent to estimated                 
          market rate fees for PCPs and SCPs, respectively.                           
                    7.  Health Choice                                                 
               Petitioner’s Health Choice plan offered enrollees access to            
          a panel of 2,600 PCPs and SCPs along with the option to use an              
          independent physician or facility.  Health Choice enrollees                 
          choosing Health Choice physicians or facilities received higher             
          “preferred” levels of service, whereas Health Choice enrollees              
          choosing non-Health Choice physicians or facilities received                
          lower “standard” benefits.                                                  
               Petitioner compensated Health Choice PCPs and SCPs on a                
          discounted fee-for-service basis.  During 1999, petitioner                  
          applied discounts of 23 percent and 28 percent to estimated                 
          market rate fees for PCPs and SCPs, respectively.                           
                    8.  IHC Access                                                    
               Petitioner entered into a so-called risk contract9 with the            
          Utah Department of Health (Department), effective January 1, 1995           
          through June 30, 1999, under which it agreed to arrange for the             
          9  42 C.F.R. sec. 447.361 (2000) states: “Under a risk contract,            
          Medicaid payments to the contractor, for a defined scope of                 
          services to be furnished to a defined number of recipients, may             
          not exceed the cost to the agency of providing those same                   
          services on a fee-for-service basis, to an actuarially equivalent           
          nonenrolled population group.”                                              
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