On behalf of our 20,000 members, the New Jersey Business & Industry Association (NJBIA), respectfully OPPOSES Assembly Bill 1977 (Prieto, Mukherji, Benson, Vainieri
Huttle). This bill requires health benefits coverage for mammograms for women under 40 who lack access to family medical history due to their or their parent’s adoption. We
would respectfully request that Assembly Bill 1977 be held to allow for full consideration of the findings of the Mandated Health Benefits Advisory Commission.
The Association places a strong and consistent focus on the quality and affordability of health insurance in New Jersey. The cost of providing health coverage to employees is one of the most significant challenges facing employers today. It is consistently ranked the number one concern facing our members in our annual NJBIA Business Outlook Survey.
NJBIA appreciates that a similar version of Assembly Bill 1977 was reviewed by the Mandated Health Benefits Advisory Commission (MHBAC) as required by P.L. 2003, c.193. The MHBAC provides an objective assessment of proposed legislation that would mandate healthcare benefits based upon their social, financial and medical impacts.
The MHBAC’s report on Senate Bill 1239 of 2012-13, raised some concerns about the necessity and effectiveness of the measure:
- Mammography is an important component of screening to detect and treat breast cancer at an early age. Family history is an important component in determining when mammography should take place. Carriers already cover screening, diagnosis, and treatment for breast cancer to a much wider extent than the minimums in the law. This includes screening mammography for women under the age of 40 when recommended by the provider.
- On the average, a woman has an approximately 1 in 8 chance of developing breast cancer over her lifetime. The incidence of breast cancer increases markedly with age. A woman aged 40 has about 25 times the chance of developing breast cancer in the next 10 years as a woman aged 20.
- Various organizations differ in their recommendations for routine screening in terms of starting age (40 or 50) and frequency (annually or less frequently). …ACOG, the American Cancer Society (ACS), the National Comprehensive Cancer Network (NCCN) and the National Cancers Institute (NCI) all recommend screening beginning at age 40. The US Preventive Services Task Force (USPSTF) recommends starting age of 50. Three of the organizations recommended annual screening. The NCI recommends screening every one to two years and the USPSTF recommends screening every two years.
- A separate ACOG Bulletin discusses the relationship between family history and the appropriateness of screening mammography for women younger than age 40. To summarize, when a BRCA1 or BRCA2 mutation is known (as a result of testing) to be present, surveillance or enhanced screening is an option, as are treatments such as chemoprevention or prophylactic surgery. Recommended surveillance includes: semiannual clinical examination, annual mammography, and annual MRI, with imaging beginning at the earlier age of 25 or earliest cancer onset from family history.
- The negative aspects of screening mammography in women younger than age 40 are cost, radiation exposure, the anxiety and cost of false positive results, and ineffectiveness or failure to detect tumors due to breast tissue density or to detect tumors in a timely manner due to rapid growth in the interval between screenings. Cost implications are discussed separately in this report.
- The MHBAC did not conclude that the mandate would be likely to result in increased healthcare costs. It found that based on 2010 data mammography screening costs totaled $46,819,000 of the more than $7 billion dollars in premiums paid. Further, it found that it was “unlikely that providers will order, or that carriers will pay for, a significant number of additional mammograms for women younger than age 40 as a result of this mandate…the estimate is $1 million for the entire regulated commercial market.”
For these reasons, we respectfully ask that this legislation be held for full consideration of the findings of the Mandated Health Benefits Advisory Commission. Thank you for your
consideration of our comments.