I
103D CONGRESS
1ST SESSION
H. R. 2089
To promote the use of State-coordinated health insurance buying programs
and assist States in establishing Health Insurance Purchasing Coopera-
tives, through which small employers may purchase health insurance,
and for other purposes.
IN THE HOUSE OF REPRESENTATIVES
MAY 12, 1993
Mr. BROWN of California introduced the following bill; which was referred
jointly to the Committees on Energy and Commerce, Ways and Means,
and the Judiciary
A BILL
To promote the use of State-coordinated health insurance
buying programs and assist States in establishing Health
Insurance Purchasing Cooperatives, through which small
employers may purchase health insurance, and for other
purposes.
Be it enacted by the Senate and House of Representa-
tives of the United States of America in Congress assembled,
SECTION 1. SHORT TITLE.
This Act may be cited as the ‘‘Health Insurance
Purchasing Cooperatives Act’’.
SEC. 2. HEALTH INSURANCE PURCHASING COOPERATIVES
GRANT PROGRAM.
(a) IN GENERAL.—The Secretary shall award grants
to States, which submit applications and otherwise meet
the requirements of this Act, to assist such States in es-
tablishing coordinated buying programs through which
small employers may purchase health insurance for their
employees.
(b) APPLICATION REQUIREMENTS.—To be eligible to
receive a grant under this section, a State shall prepare
and submit to the Secretary an application in such form,
at such time, and containing such information, certifi-
cations, and assurances as the Secretary shall reasonably
require, including a certification that—
(1) the State has, through State law, executive
order, or regulation, initiated the steps necessary to
establish a coordinated buying program that meets
the requirements of subsection (d), through which
each small employer in the State desiring to pur-
chase health insurance for its employees shall pur-
chase such insurance; or
(2) in the case of a State which the Secretary
identifies, in consultation with the National Associa-
tion of Insurance Commissioners, as—
(A) requiring State legislation (other than
legislation appropriating funds) to establish a
coordinated buying program that meets the re-
quirements of subsection (d); and
(B) having a legislature that does not meet
during the first year after the date of enact-
ment of this Act in a legislative session in
which such legislation may be considered;
the State has established a plan, to be fully imple-
mented not later than 2 years after the date on
which the grant is awarded to such State by the
Secretary, for the establishment of a coordinated
buying program that meets the requirements of sub-
section (d).
(c) USE OF FUNDS.—Amounts awarded under this
section may be used to finance the administrative costs
associated with planning, developing, and implementing a
coordinated buying program, comprised of one or more
Health Insurance Purchasing Cooperatives, for small em-
ployers. Such administrative costs may include the costs
associated with—
(1) engaging in education and outreach efforts
to inform small employers, carriers, and the public
about the coordinated buying program;
(2) soliciting bids and negotiating with carriers
to make available health benefit plans, consistent
with section 3, through the coordinated buying pro-
gram and one or more Health Insurance Purchasing
Cooperatives; and
(3) preparing and disseminating the docu-
mentation required by Federal agencies to certify
participation in the coordinated buying program and
one or more Health Insurance Purchasing Coopera-
tives.
(d) COORDINATED BUYING PROGRAM.—To receive
funding under this section, a State coordinated buying
program shall—
(1) be authorized and enforced under State law,
executive order, or regulation as the sole mechanism
through which health insurance for employees of
small employers shall be purchased in such State;
(2) provide each small employer in the State
with access to health insurance for its employees and
their dependents, through one or more Health Insur-
ance Purchasing Cooperatives qualified under sub-
section (e);
(3) require that each Health Insurance Pur-
chasing Cooperative participating in the State co-
ordinated buying program meet the requirements of
section 5 with respect to reporting data to a Re-
gional Data Collection Center and participating in
the National Health Insurance Data System; and
(4) meet such other criteria as reasonably re-
quired by the Secretary, the National Health Board,
or mandated under this Act.
(e) HEALTH INSURANCE PURCHASING COOPERA-
TIVE.—
(1) REQUIREMENTS.—To be a qualified Health
Insurance Purchasing Cooperative an entity shall—
(A) be a nonprofit entity established and
regulated in accordance with State law in a
manner that will ensure an economy of scale
based on the State’s geographic and demo-
graphic characteristics;
(B) be designated by the State as the ex-
clusive agent for purchasing, coordinating, and
administering services among carriers on behalf
of small employers and their employees within
a defined geographic area (hereafter referred to
in this section as a ‘‘district’’);
(C) except as provided under paragraph
(3), certify that it will not contract with any
carriers that deny, limit, or condition coverage
under (or benefits of) the plan based on the
health status, claims experience, receipt of
health care, medical history or lack of evidence
of insurability, of an individual;
(D) after the date that is 2 years after the
date of enactment of this Act, certify that it
will not contract with any carriers that do not
meet the minimum benefits requirements estab-
lished by the National Health Board under sec-
tion 4;
(E) not less than annually, hold an open
enrollment period for all employees covered by
the Health Insurance Purchasing Cooperative
health benefit plans;
(F) use adjusted community ratings (under
which the only factors that may be applied are
age, gender, and geography within a district) to
determine the cost for each covered employee or
dependent; and
(G) meet such other criteria as reasonably
required by the State or the Secretary, or man-
dated under this Act.
(2) ACTIVITIES.—Within its district, each
Health Insurance Purchasing Cooperative shall—
(A) provide for the comprehensive purchas-
ing of health insurance and services for all
small employers;
(B) act as an agent for the small employ-
ers and, based on the recommendations of the
National Health Board, assist the small em-
ployers, employees, and dependents in determin-
ing appropriate health benefit plans;
(C) solicit bids from and contract with car-
riers for specific health benefit plans, which
shall include those benefits determined by the
National Health Board under section 4, and,
notwithstanding any other provision of Federal
or State law—
(i) hold confidential proprietary infor-
mation upon which estimates on bids are
derived; and
(ii) issue contracts only to those car-
riers providing both cost effective and
quality health benefits, plans, and services;
(D) administer all aspects of health insur-
ance coverage for all small employers, their em-
ployees and dependents, including routine
health benefits, COBRA benefits, relevant Fed-
eral health insurance earned income tax credits,
and the collection of premiums paid under sec-
tion 1906 of the Social Security Act;
(E) inform employees and dependents
about their benefits, rights, and responsibilities
and enable employees and dependents to select
benefits based on standardized plans that com-
pete in cost and quality; and
(F) in a timely fashion, report, as required
by section 5, all relevant data, including health
outcomes data, to the appropriate Regional
Health Insurance Data Collection Center.
(3) EXCLUSION OF COVERAGE.—Notwithstand-
ing paragraph (1)(C), a Health Insurance Purchas-
ing Cooperative may, in accordance with this sub-
section, contract with a carrier for a health benefit
plan that limits exclusion of coverage, with respect
to services related to treatment of a preexisting con-
dition, to a period not exceeding 6 months. The ex-
clusion of coverage shall not apply to services fur-
nished to newborns.
(f) RELATION TO OTHER LAWS.—
(1) ANTITRUST
LAWS.—Notwithstanding any
provision of the antitrust laws, it shall not be consid-
ered a violation of the antitrust laws for a State, in
accordance with this section, to develop a State co-
ordinated buying program comprised of Health In-
surance Purchasing Cooperatives, or for any carrier,
in accordance with this section, to participate in
such a program or Cooperative.
(2) DEFINITION.—For purposes of this section,
the term ‘‘antitrust laws’’ means—
(A) the Act entitled ‘‘An Act to protect
trade and commerce against unlawful restraints
and monopolies’’, approved July 2, 1890, com-
monly known as the ‘‘Sherman Act’’ (26 Stat.
209; chapter 647; 15 U.S.C. 1 et seq.);
(B) the Federal Trade Commission Act,
approved September 26, 1914 (38 Stat. 717;
chapter 311; 15 U.S.C. 41 et seq.);
(C) the Act entitled ‘‘An Act to supple-
ment existing laws against unlawful restraints
and monopolies, and for other purposes’’, ap-
proved October 15, 1914, commonly known as
the ‘‘Clayton Act’’ (38 Stat. 730; chapter 323;
15 U.S.C. 12 et seq.; 18 U.S.C. 402, 660,
3285, 3691; 29 U.S.C. 52, 53); and
(D) any State antitrust laws that would
prohibit the activities described in paragraph
(1).
(g) AUTHORIZATION
OF APPROPRIATIONS.—There
are authorized to be appropriated to carry out this section,
$25,000,000 for fiscal year 1994, and $30,000,000 for
each of the fiscal years 1995 through 1998.
SEC. 3. NATIONAL HEALTH BOARD.
(a) IN GENERAL.—There is hereby established a Na-
tional Health Board (hereafter referred to in this section
as the ‘‘Board’’) which shall be composed of 11 members
to be appointed by the President by and with the advice
and consent of the Senate not later than 6 months after
the date of enactment of this Act.
(b) MEMBERSHIP.—
(1) REPRESENTATION.—The membership of the
Board shall include individuals with national rec-
ognition for their expertise in health insurance,
health economics, health care provider reimburse-
ment, and related fields. In appointing individuals
under subsection (a), the President shall assure rep-
resentation of consumers of health services, large
and small employers, State and local governments,
labor organizations, and health care providers and
carriers.
(2) CHAIRPERSON.—The members of the Board
shall elect a Chairperson.
(3) TERMS.—Members of the Board shall be
appointed to serve for terms of 6 years, except that
the terms of the members first appointed shall be
staggered so that the terms of no more than 4 mem-
bers expire in any year. The term of the Chairperson
shall be coincident with the term of the President.
Individuals appointed to fill a vacancy created in the
Board shall be appointed for the remainder of the
term.
(c) DUTIES.—
(1) PRECEPTS.—The Board shall establish Co-
ordinated Buying Program Precepts, that shall set
forth criteria for—
(A) establishing a uniform data system
that will assist in designating qualified Health
Insurance Purchasing Cooperatives and car-
riers;
(B) determining and implementing a sys-
tem for the collection of relevant health out-
comes data, including quality monitors, func-
tional 
status, 
expense 
reporting 
methods
(including the costs associated with providing
services within State coordinated buying pro-
gram), demographic and behavioral measures,
and changes in clinical conditions as a result of
therapeutic interventions expressed in Quality
Life Years in a manner that assumes confiden-
tiality of patient information; and
(C) determining and revising, if necessary,
appropriate minimum benefit requirements of a
qualified health benefit plan, consistent with
section 4 and developing additional benefit
plans as necessary to provide more extensive
benefits.
(2) SCIENTIFIC
BASIS.—To the extent prac-
ticable, the precepts of the Board shall be derived
from an evaluation of the extant scientific literature
and outcome data collected under this Act.
(3) ASSISTANCE TO SECRETARY.—The Board
shall make written recommendations on at least an
annual basis to the Secretary and the States in the
planning, development, and implementation of all
components of the National Health Insurance Data
System established under section 5, including the
determination of health outcomes data to be col-
lected through the standardized universal electronic
card, and shall provide such other assistance as the
Secretary or the States may request.
(d) MISCELLANEOUS.—
(1) AUTHORITY.—The Board may—
(A) employ and fix the compensation of an
Executive Director and solicit other personnel
(not to exceed 15) as may be necessary to carry
out its duties (without regard to the provisions
of title 5, United States Code, governing ap-
pointments in the competitive service);
(B) seek such assistance and support as
may be required in the performance of its du-
ties from appropriate Federal departments and
agencies;
(C) enter into contracts or make other ar-
rangements, as may be necessary for the con-
duct of the work of the Board (without regard
to section 3709 of the Revised Statutes (41
U.S.C. 5)); and
(D) make advance, progress, and other
payments which relate to the work of the
Board.
(2) COMPENSATION.—While serving on the
business of the Board (including traveltime), a mem-
ber of the Board shall be entitled to compensation
at the per diem equivalent of the rate provided for
level IV of the Executive Schedule under section
5315 of title 5, United States Code, and while so
serving away from the member’s home and regular
place of business, a member may be allowed travel
expenses, as authorized by the Chairperson of the
Board.
(3) ACCESS
TO
INFORMATION, 
ETC.—The
Board shall have access to such relevant information
and data as may be available from appropriate Fed-
eral agencies and shall assure that its activities, es-
pecially the conduct of original research and medical
studies, are coordinated with the activities of Fed-
eral agencies. The Board shall be subject to periodic
audit by the General Accounting Office.
(4) AUTHORIZATION
OF
APPROPRIATIONS.—
There are authorized to be appropriated, $500,000
for each of the fiscal years 1994 through 1998.
SEC. 4. HEALTH BENEFITS.
(a) ESTABLISHMENT OF REQUIREMENTS.—Not later
than 18 months after the date of enactment of this Act,
the National Health Board shall establish minimum bene-
fit requirements for health benefit plans offered through
Health Insurance Purchasing Cooperatives. Such mini-
mum benefits shall include—
(1) inpatient and outpatient hospital care, ex-
cept that treatment for a mental disorder is subject
to the special limitations described in paragraph
(6)(A);
(2) inpatient and outpatient physician services,
except that psychotherapy or counseling for a mental
disorder is subject to the special limitations de-
scribed in paragraph (6)(B);
(3) diagnostic tests;
(4) prenatal care and well-baby care provided to
children who are 1 year of age or younger;
(5) preventive and early intervention services,
including—
(A) well child care;
(B) pap smears; and
(C) mammograms; and
(6)(A) inpatient hospital care for a mental dis-
order for not less than 45 days per year, except that
days of partial hospitalization, residential care, or
outpatient treatment may be substituted for days of
inpatient care according to a ratio established by the
Board; and
(B) outpatient psychotherapy and counseling
for a mental disorder for not less than 20 visits per
year provided by a provider who is acting within the
scope of State law and who—
(i) is a physician; or
(ii) meets the standards of subsection
(e)(2)(B) and is a duly licensed or certified clin-
ical psychologist or a duly licensed or certified
clinical social worker, a duly licensed or cer-
tified equivalent mental health professional, or
a clinic or center providing duly licensed or cer-
tified mental health services.
(b) EXCEPTIONS.—Subsection (a) shall not be con-
strued as requiring the Board to specify that a plan in-
clude payment for—
(1) items and services that are not medically
necessary; or
(2) experimental services and procedures, ex-
cept that the Board may include coverage of routine
medical costs associated with peer-reviewed and ap-
proved protocols conducted in connection with peer-
reviewed and approved research programs, pursuant
to standards established by the Board.
(c) AMOUNT, SCOPE, AND DURATION OF CERTAIN
BENEFITS.—Except as provided in subsection (b), a
health benefit plan shall place no limits on the amount,
scope, or duration of benefits described in paragraphs (1)
through (3) of subsection (a).
(d) LIMITATIONS.—
(1) PANELS AND MANAGED CARE SYSTEMS.—
Nothing in this section or this Act shall prohibit a
health benefit plan from providing benefits for the
items and services described in this section through
a managed care system, and from selecting particu-
lar health care providers or types, classes, or cat-
egories of health care providers to participate in
such managed care system. Such managed care sys-
tem shall provide reasonable access, as defined by
the Board, to care by plan enrollees.
(2) DIFFERENT LEVELS OF PAYMENTS.—Noth-
ing in this section or this Act shall prohibit a health
benefit plan from establishing a different level of
payments for reimbursement for different health
care providers furnishing the benefits for the items
and services described in this section.
(3) DENIAL OF PAYMENT TO EXCLUDED PRO-
VIDERS.—Nothing in this section or this Act shall
require a health benefit plan to make payment to
any health care provider that is excluded from par-
ticipation in any Federal health care program.
(e) MENTAL HEALTH CARE.—
(1) INPATIENT
CARE.—Subject to the provi-
sions of subsection (d), inpatient hospital care de-
scribed in subsection (a)(6)(A) shall include reim-
bursement for professional care provided to the indi-
vidual while the individual is receiving such inpatient
care, by a physician or duly licensed or certified clin-
ical psychologist operating within the scope of prac-
tice of the physician or psychologist, as determined
appropriate under State law. Nothing in this sub-
section shall be construed to modify hospital prac-
tices with regard to scope of practice, admitting
privileges, or billing arrangements.
(2) OUTPATIENT CARE.—
(A) USE OF PROVIDERS.—Subject to the
provisions of subsection (d), a health benefit
plan that provided benefits with respect to out-
patient psychotherapy described in subsection
(a)(6)(B) prior to January 1, 1994, shall not be
required under such subsection to provide bene-
fits for outpatient psychotherapy provided by
any health care provider (or type, class, or cat-
egory of health care provider) described in sub-
section (a)(6)(B)(ii), other than duly licensed or
certified clinical psychologists and health care
providers being used by the plan on January 1,
1994.
(B) STANDARDS
FOR
CERTAIN
PROVID-
ERS.—The Board shall establish standards that
providers referred to in subsection (a)(6)(B)(ii)
must meet to be eligible for payment under a
health benefit plan and such standards shall re-
quire that such providers have training and
education equivalent to a licensed clinical social
worker (as defined in title XVIII of the Social
Security Act).
(f) ADDED BENEFIT PLANS.—Not later than 24
months after the date of enactment of this Act, the Board
shall establish minimum benefit requirements for two ad-
ditional health benefit plans that—
(1) shall provide benefits more extensive or
more innovative than those provided by the plan de-
veloped under subsection (a); and
(2) may be compared on the basis of cost and
quality outcome measures.
(g) STUDIES.—
(1) INITIAL REPORT.—Not later than 3 years
after the date of enactment of this Act, the Board
shall—
(A) review the appropriateness of the mini-
mum benefits and services required to be cov-
ered under subsection (a); and
(B) prepare and submit to the Secretary
and the appropriate committees of Congress a
report concerning the cost-effectiveness and de-
sirability of such benefits and services and mak-
ing recommendations for changes in the list of
such benefits and services.
(2) BIENNIAL REPORT.—Not later than 2 years
after the date on which the report is submitted
under paragraph (1), and every 2 years thereafter,
the Board shall prepare and submit to the Secretary
and the appropriate committees of Congress a report
updating the preceding report and reviewing, con-
sistent with paragraph (1), the additional benefits
and services included in the plans developed under
subsection (f).
(h) EXEMPTION FROM HMO REQUIREMENTS.—Sec-
tion 1301 of the Public Health Service Act (42 U.S.C.
300e) is amended by adding at the end thereof the follow-
ing new subsection:
‘‘(d) The provisions of this title relating to health
services offered by a health maintenance organization shall
not apply with respect to those health maintenance organi-
zations that provide services that meet the requirements
for health insurance plans offered through Health Insur-
ance Purchasing Cooperatives under section 4 of the
Health Insurance Purchasing Cooperatives Act.’’.
SEC. 5. NATIONAL HEALTH INSURANCE DATA SYSTEM.
(a) IN GENERAL.—Using advanced technologies to
the maximum extent practicable, the Secretary shall estab-
lish and maintain a National Health Insurance Data Sys-
tem, which shall be comprised of—
(1) a centralized National Data Base for
Health Insurance and Health Outcomes Informa-
tion;
(2) a network of no more than five Regional
Health Insurance Data Collection Centers; and
(3) a standardized, universal mechanism for
electronically processing health insurance and health
outcomes data.
(b) NATIONAL DATA BASE FOR HEALTH INSURANCE
INFORMATION.—The National Data Base for Health In-
surance Information shall—
(1) be centrally located;
(2) rely on advanced technologies to the maxi-
mum extent practicable; and
(3) be readily accessible by each State coordi-
nated buying program for data input and retrieval.
(c) REGIONAL HEALTH INSURANCE DATA COLLEC-
TION CENTERS.—The Secretary shall designate not more
than five regional centers, to be located throughout the
United States, for the initial collection and analysis of
data on each State coordinated buying program, as de-
scribed in section 3(c)(1)(B), and such other information
as determined useful to the Secretary or the National
Health Board. The regional centers shall transmit relevant
data, as determined appropriate by the Secretary and the
National Health Board, to the National Data Base for
Health Insurance and Health Outcomes Information.
(d) ELECTRONIC DATA COLLECTION CARD.—The
Secretary, upon the recommendation of the National
Health Board, shall—
(1) establish uniform billing and claims forms
and mandatory reporting requirements, including in-
formation on member eligibility, benefits, use, out-
comes, and efficacy, which shall be adopted for use
by each State and State coordinated buying program
receiving funding under section 2; and
(2) ensure that no State receives funding under
this Act if carriers in such State do not agree to
issue to each participant in the State coordinated
buying program an electronic data processing card
approved by the Secretary that shall—
(A) contain information on billing, eligi-
bility, and other financial, administrative, and
health outcomes matters, as determined nec-
essary by the Secretary and the National
Health Board, which can be conveyed electroni-
cally to a regional data processing center; and
(B) enable health care providers to enter
information into a participant’s file concerning
administrative matters, treatment, such as di-
agnosis based on standard codes, and outcome,
except that participating health care providers
must agree to provide data in standard format,
which shall be established by the Secretary and
the National Health Board.
(e) RELIGIOUS OBJECTIONS.—Nothing in this Act
shall be construed to require any State coordinated buying
program or Health Insurance Purchasing Cooperative to
compel any person to undergo any medical screening, ex-
amination, diagnosis, or treatment or to accept any other
health care or services provided under a health benefit
plan for any purpose (other than for the purpose of discov-
ering and preventing the spread of infection or contagious
disease or for the purpose of protecting environmental
health), if such person objects (or, in case such person
is a child, his parent or guardian objects) thereto on
religious grounds.
(f) CONFIDENTIALITY.—The Secretary, upon the rec-
ommendation of the National Health Board, shall ensure
that all patient information collected under this section is
managed so that confidentiality is protected.
(g) AUTHORIZATION
OF APPROPRIATIONS.—There
shall be authorized to be appropriated, annually,
$1,000,000 for fiscal years 1994 through 1998.
SEC. 6. DEFINITIONS.
As used in this Act:
(1) CARRIER.—The term ‘‘carrier’’ means any
person or entity that offers a health benefit plan,
whether through insurance or otherwise, including a
licensed insurance company, a prepaid hospital or
medical service plan, or a health maintenance
organization.
(2) ELIGIBLE EMPLOYEE.—The term ‘‘eligible
employee’’ means, with respect to an employer, an
employee who normally performs on a monthly basis
at least 30 hours of service per week for that
employer.
(3) 
HEALTH
BENEFIT
PLAN.—The 
term
‘‘health benefit plan’’ means any hospital or medical
service policy or certificate, hospital or medical serv-
ice plan contract, or health maintenance organiza-
tion group contract, but does not include any of the
following offered by a carrier—
(A) accident only, dental only, disability
only 
insurance, 
or 
long-term 
care 
only
insurance;
(B) coverage issued as a supplement to li-
ability insurance;
(C) workmen’s compensation or similar in-
surance; or
(D) 
automobile 
medical-payment
insurance.
(4) HEALTH
MAINTENANCE
ORGANIZATION.—
The term ‘‘health maintenance organization’’ has the
meaning given the term ‘‘eligible organization’’ in
section 1876(b) of the Social Security Act.
(5) NAIC.—The term ‘‘NAIC’’ means the Na-
tional Association of Insurance Commissioners.
(6) PREEXISTING CONDITION.—The term ‘‘pre-
existing condition’’ means, with respect to coverage
under a health benefit plan issued to a small em-
ployer, employee or dependent by a carrier, a condi-
tion which has been diagnosed or treated during the
3-month period ending on the day before the first
date of such coverage (without regard to any waiting
period).
(7) SECRETARY.—The term ‘‘Secretary’’ means
the Secretary of Health and Human Services.
(8) SMALL EMPLOYER.—The term ‘‘small em-
ployer’’ means, with respect to a calendar year, an
employer that normally employs at least 1 but less
than 51 eligible employees on a typical business day.
For the purposes of this paragraph, the term ‘‘em-
ployer’’ includes a self-employed individual.
SEC. 7. INCREASE IN DEDUCTIBLE HEALTH INSURANCE
COSTS FOR SELF-EMPLOYED INDIVIDUALS
FOR INSURANCE PURCHASED THROUGH A
HEALTH 
INSURANCE 
PURCHASING
COOPERATIVE.
(a) IN GENERAL.—Paragraph (1) of section 162(l)
of the Internal Revenue Code of 1986 (relating to special
rules for health insurance costs of self-employed individ-
uals) is amended by striking ‘‘equal to’’ and all that fol-
lows and inserting the following: ‘‘equal to—
‘‘(A) 100 percent of the amount paid dur-
ing the taxable year for insurance which is pur-
chased through a Health Insurance Purchasing
Cooperative under the Health Insurance Pur-
chasing Cooperatives Act and which constitutes
medical care for the taxpayer, his spouse, and
dependents, and
‘‘(B) 25 percent of the amount paid during
the taxable year for insurance not described in
subparagraph (A) which constitutes medical
care for the taxpayer, his spouse, and depend-
ents.’’.
(b) PERMANENT DEDUCTION.—Section 162(l) of
such Code is amended by striking paragraph (6).
(c) EFFECTIVE DATE.—The amendments made by
this section shall apply to taxable years beginning after
December 31, 1993.
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