Centinela Freeman Emergency Med. Assocs. v. Health Net of California, Inc. (Summary)

MANAGED CARE

Centinela Freeman Emergency Med. Assocs. v. Health Net of California, Inc., No. B238867 (Ca. Ct. App. 2nd Dist., Div. 3 Feb. 19, 2014)

Several groups of emergency medicine physicians and a group of radiologists were not paid for the services they rendered to patients covered by an HMO because the IPA to which the HMO delegated its responsibility to reimburse physicians was having financial difficulties.  The physicians sued the HMO for, among other things, negligent delegation.  The California Court of Appeal held that an HMO has a duty not to delegate its obligation to reimburse emergency physicians to an IPA that it knows will be unable to do so.  The court sent the case back to the lower court for further proceedings.