August 4, 2023 David Caldwell Executive Counsel Louisiana Department of

The company’s articles of incorporation note that its purpose is to “promote the welfare of the members of the Corporation and the general public.” On its website and in press releases, BCBSLA states that its mission is “to improve the health and lives of Louisianans.” BCBSLA recognizes this public purpose by proposing to use most of its current assets to establish a foundation - the Accelerate Lo. [...] The law says eligible groups must be “operated exclusively for the promotion of social welfare.” Over time, the meaning of this term came to include nonprofits “operated primarily for the purpose of bringing about civic betterments and social improvements.” More importantly, those groups—which are not required to reveal the identities of their donors—have long been permitted to take part in an unl. [...] Moreover, according to Exhibit G in the Plan of Reorganization, the four directors of this new foundation would come directly from the current BCBSLA Board of Directors. [...] Additionally, the new foundation should be governed by a Board that reflects, to the greatest extent possible, Louisiana’s geographic, racial, economic and gender diversity, and where fewer than 50% of the Board has direct ties to the health insurance industry. [...] Building on that research, the Commissioner should commission an independent analysis to determine the risk of higher costs to policyholders - in premiums, deductibles and copays, as a result of the reorganization.