This bulletin is a follow-up to the August, 2017 King & Spalding Client Alert, “California’s Surprising New ‘No Surprise’ Health Care Billing Law” (“August Alert”).

As described in our August Alert, California’s new “No Surprise” billing law required the California’s Department of Managed Health Care(“DMHC”) and Department of Insurance (“DOI”) to develop dispute resolution processes for handling rate disputes between health plans and individual health professionals (“IHPs”), including physicians and other clinicians who are not contracted with their patients’ health plans or insurers but who practice at hospitals and other facilities that are contracted, i.e., “in network.” See Cal. Health & Safety Code §§ 1371.9(f)(3), 1371.30; Cal. Ins. Code §§ 10112.8(f)(3), 10112.81 (“AB 72”). The DMHC and DOI have now developed their AB 72 processes, which differ in significant ways.