Transcript of Coverage Initiation Conference Call: “Multiplan, a PBM for Out-of-Network Healthcare Services or an ‘Independent’ Pricing Standard?”

Mar 11, 2022

On March 4, The Capitol Forum hosted a conference call with our corporate investigations team to discuss their recent article, “Multiplan’s ‘Independent’ Prices Can Be Set by Insurers, Sources Allege; Evidence in Nevada Jury Trial Corroborates Allegation.” The full transcript, which has been modified slightly for accuracy, can be found below.

TEDDY DOWNEY: Good afternoon, everyone. Thanks for joining The Capitol Forum’s conference call to discuss our recent article on MultiPlan. The article was called “MultiPlan’s Independent Prices Can Be Set by Insurers Sources Allege; Evidence in Nevada Jury Trial Corroborates Allegations.”

I’m Teddy Downey, Executive Editor here at The Capitol Forum, and I’m joined today by the authors of that article, Lisa Epstein and Vikas Kumar.

A quick note before we get underway. For the first 20 minutes or so, I’ll interview Lisa and Vikas. Then we’ll move into a Q&A format where we will entertain questions from the audience. If you have questions for us, please email them to Vikas, Lisa, great to be here and chatting with you about this.

VIKAS KUMAR: Thanks for having us.

LISA EPSTEIN: Thank you, Teddy.

TEDDY DOWNEY: So I think maybe the easiest way to sort of go through this piece is to let you tell me the story, tell our audience the story, of the history of this market going back to Ingenix, which was the data provider for these kinds of prices that MultiPlan provides before there was MultiPlan. So we’d love to hear a history of how this market works.

LISA EPSTEIN: So what came out from Cuomo’s investigation was he was going around, 2008, around New York, asking New Yorkers what their main concerns and issues were that his office could look into. And something that came up over and over and over again was medical health care costs, especially in regard to out‑of‑network bills that patients just couldn’t piece together, understand, and they were responsible for these huge bills. Now, remember, this was well before the Affordable Care Act.

TEDDY DOWNEY: And these bills, you’re talking about surprise billing basically, where people get—

LISA EPSTEIN: Yes, billed. So for out-of-network health care claims, if someone has a health plan that covers out-of-network care, what typically happens is there’s a percentage of the bill that the insurer pays and the patient is responsible for the rest because the provider does not have a contract with the health care plan for a certain rate. At the time of this Ingenix story came to light, the way that out-of-network bills were paid were based on what’s called the usual and customary rate, supposedly a market rate. And there were various ways to calculate that. But Ingenix was a database company, a subsidiary of UnitedHealthcare. And Ingenix would generate what was said to be fair and reasonable rates for insurers to pay out of network claims on.

And so Ingenix would generate a rate and then the health care plan would pay a percent of that rate to the provider, leaving the balance for the patient. And patients are aware of that. But what they weren’t aware of was an unexpectedly high portion of the bill was their responsibility, and they couldn’t figure out why, when they had expected to only pay a certain portion of the bill. And then all of a sudden they are asked to be paying a higher percent or chip in much more.

So Cuomo’s office started an investigation in 2008 into what was going on. And his investigation found out that what was happening with Ingenix was insurance companies were submitting altered or tampered claim data. They were shaving off the highest payment amounts to artificially suppress the average rate. And other methodologies of essentially ensuring the rates that came out of Ingenix were artificially low. And so an artificially low rate would be generated by Ingenix and insurance would pay the plan percentage, leaving the patient with a much higher percentage of the bill.

So when his investigation found this information out, he went to the insurance companies and first United agreed to stop using Ingenix, basically shut down Ingenix. And all of the other insurance companies agreed not to use Ingenix rates anymore, as well as chip in—all the insurance companies chipped into this independent database, now called Fair Health. Anyone can look that up and the rates. With the intent of industry‑wide reform, that there would be a transparent rate that anyone could look up and see what a fair charge, fair average charge, for your geographic area would be for specific services, for in-network health care services and out-of-network health care services.

TEDDY DOWNEY: And so just to kind of quickly recap. Ingenix was not providing fair, independent prices, but was providing insurer manipulated prices. Cuomo found out and cracked down on it and replaced Ingenix with a nonprofit entity that was going to actually provide fair independent prices, that would be what the insurers would pay when they got these out of network claims. Is that kind of a fair recap?

LISA EPSTEIN: Right. And then they would pay a percentage based on the plan. So if your plan says we’ll pay 80 percent of an out-of-network bill and you’re responsible for 20 percent, they’re not actually saying they’ll pay it based on the bill. They’ll say they’ll pay it based on a fair and reasonable market rate. So as part of the settlement, United was going to go by Ingenix’ rates for five years. They agreed to five years I think.

TEDDY DOWNEY: No, they were going to go by the new—not Ingenix rate.

LISA EPSTEIN: Oh, not Ingenix, I’m sorry.

TEDDY DOWNEY: They had a settlement for five years. And they were going to use the fair independent rate set by this nonprofit as part of the settlement, correct?

LISA EPSTEIN: Correct. Yes, I’m sorry. Correct.

TEDDY DOWNEY: So Cuomo comes in and forces a—and maybe, Vikas, maybe you could just tell us a little bit about this case, a little bit about what Cuomo alleged and maybe just kind of give us a little color on that.

VIKAS KUMAR: Sure, yeah. So Cuomo issued a notice of litigation that’s publicly available and can be read. And basically, he alleged that instead of independently determining what the rates were or should have been, United was using a company it owned which United knew was setting inappropriate rates and that their interests were aligned to keep the rates artificially low to benefit United.

And one of the problems with Ingenix is that United failed to disclose that they were relying on this database that Ingenix was putting together and the fact that United owned Ingenix. And so the allegations of improper practices are under New York insurance law, but basically allege that you engaged in deceptive practices and also that it’s possible that there may not have been all the information disclosed to people in making decisions about which insurance providers to use.

TEDDY DOWNEY: Okay, perfect. And so this settlement happens. They reshape the industry. They stop the manipulated prices. They go to fair prices for five years. And from all accounts, from what you guys saw, they didn’t have this problem for five years. This problem basically kind of went away for five years. Is that fair to say? Or it became a dramatic, there really wasn’t an issue here because the reform seemed to work.

LISA EPSTEIN: From what I’ve seen, the reform did seem to work for at least those five years, for about those five years. That’s what I’ve seen.

TEDDY DOWNEY: Yeah. So then the five years are up and then what happens?

LISA EPSTEIN: So the five years are up, and then United began talks with MultiPlan to figure out an alternative system to the Fair Health rates and that’s basically what they did. They just migrated from Fair Health over to MultiPlan’s price setting services.

TEDDY DOWNEY: So MultiPlan effectively emerges out of the sort of end of the Cuomo’s settlement. Is that kind of a fair way to characterize what you guys found?

LISA EPSTEIN: Well, MultiPlan actually has been around for about 40 years. MultiPlan started purely as, let’s say, an independent rental network. So an insurance plan might use the network of doctors that MultiPlan put together and contracted with to be part of the MultiPlan network. So a new insurance plan or an insurance plan that wants to expand their geographic footprint might rent, pay a per member per month fee, to MultiPlan to enable the health plan members to see those doctors. So that’s what MultiPlan did for decades. Starting around 2010, MultiPlan expanded into the cost management service side. And that’s when they really started—they acquired several companies and they started issuing rates that were data driven from their databases and the claims that they were seeing on their network. They started issuing rates. And at some point, it morphed into offering insurers to manipulate the rates very similar to what happened with Ingenix using different methodologies.

TEDDY DOWNEY: Got it. And how did you find out about that MultiPlan, which does say that they have fair and independent rates. A huge, huge part of their vision is to say that these rates are fair. Or I should say, it’s important to their business to say that these rates are fair and independent. How did you find out that they were being manipulated by the insurance companies?

LISA EPSTEIN: Well, I started by talking to some providers and/or billers, owners of medical billing companies, and just listening to their experience and what they were seeing. Concurrently with that, I looked at probably 50 or 60 lawsuits filed against MultiPlan and health plans and employers about alleged underpayments, providers being underpaid. As well as some lawsuits filed by patients saying that, hey, I’m on the hook for tens of thousands of dollars when I expected to be on the hook for a much smaller percentage. And I can’t get any answers that make any sense as to why I’m on the hook for a lot more than expected.

And I read these lawsuits and looked at the exhibits that had been filed in these lawsuits. And this big case in Nevada, which was brought by emergency room physician groups that are subsidiaries of TeamHealth suing United, did not name MultiPlan as a defendant, but MultiPlan’s practices and testimony about MultiPlan’s documents featured prominently in the testimony. So I read probably 3,000 pages of the trial transcript and slowly started to put together what was happening with MultiPlan’s, relationship with insurers and how they were helping insurers to artificially suppress what they’re saying are fair and independent rates for out-of-network health care services.

TEDDY DOWNEY: Got it. So the whole time MultiPlan says these are fair and independent rates, these are fair and independent rates, and when you were calling these people and when you talked to these sources and then you read the documents, walk us through how it sort of started. How did the insurers kind of start manipulating the prices a little bit? And then what did it end up effective turning into?

LISA EPSTEIN: So the providers don’t understand fully what was happening. So when I began talking to them, I obviously didn’t understand what was happening either. But they did say some very interesting and curious comments, such as everything was fine. I was billing right in line with what Fair Health says is an appropriate fair rate for my area. And I was actually getting paid based on that.

So, for example, a provider would bill $400, which would be below the Fair Health rate. The patient’s plan paid 60 percent. They would pay me $240 and the patient would pay $160. And we were going along just fine with that all through to 2020. And then all of a sudden in 2021, starting with the very first claim of 2021, I would get much less from the insurance company, maybe $90. The patient was responsible then for about$310.00. And the payment stub that came to me from the insurance company, which happened to be United Health in this case, but several other insurance companies were discussed during these conversations. The payments stub would say if you have any issues with this payment amount, call Data iSight, which is a subsidiary of MultiPlan.

And so then that would start the providers making hours and hours and hours of phone calls and appeals and attempts to figure out what had changed, and how Data iSight and MultiPlan got this new amount that they verified or justified this lower payment. The patients would be spending hours on the phone. And so I heard this type of story over and over and over again, just a sudden drop in reimbursement as soon as MultiPlan or Data iSight came onto the picture.

And as well, I also heard people that would be receiving a low reimbursement rate from a MultiPlan aligned insurer. And then all of a sudden, the rate would drop by 50 percent with no explanation, no answers and the provider be just completely unable to get any kind of response as to why they dropped the rate. So that’s really what made me start thinking that something very curious and interesting was happening.

VIKAS KUMAR: And then the only other thing I would add, if I may, we first encountered some of these practices involving Data iSight and MultiPlan, and we did work on Health Insurance Innovations a few years ago. And how in that case, what was happening was people were getting duped into buying insurance and then their claims were not being paid. And there’s been a lot of press coverage and lawsuits involving Data iSight being used to underpay some of the claims in those cases as well. So it was interesting to see some of the same practices being alleged with normal or not short-term health insurance more recently was uncovered.

TEDDY DOWNEY: Got it. Got it. And what did you learn when you were talking to sources and reading through the transcripts? What did you learn about Data iSight and the insurer’s role in Data iSight?

LISA EPSTEIN: So the TeamHealth trial out of Nevada, the testimony elicited from essentially four of the witnesses was key to me finally piecing together the pieces of this puzzle, and three were UnitedHealth executives, one’s retired and two are still at UnitedHealth, and one is an executive at MultiPlan. And piecing together excerpts from their testimony, it became very clear that MultiPlan allows insurers to set their own rates in various different ways. They have different methodologies that they offer their insurance clients. They can set a maximum rate. So if Data iSight database spits out a rate that’s higher than the maximum rate, then the default will be the maximum rate that the insurer sets. And there’s several other technical methodologies. They can set a meet or beat price. They can set a specific dollar amount price, and several other services that MultiPlan offers insurers to ensure they do not pay over an insurance company‑determined rate. And MultiPlan does not make that information easy to understand or discern from any publicly facing statements or documents that come out of plans. Nor do the insurers.

TEDDY DOWNEY: Got it. So just to recap it quickly. The insurers basically have a lot of influence over what the price ends up being in Data iSight. So once the insurers start being able to influence Data iSight’s price, the prices from MultiPlan stopped being fair and independent. Is that kind of a fair way to say what you found?

LISA EPSTEIN: Absolutely, yes.

TEDDY DOWNEY: But did they continue to—do they have a disclaimer where they say these prices are insurance influenced? Or did they have anything that indicates that those prices were changed? Or MultiPlan just say these are still MultiPlan’s fair and independent prices?

LISA EPSTEIN: Yeah, everything that I saw—well, except for one document, but everything that I saw from the insurers and from MultiPlan indicate that MultiPlan’s prices are data driven, independent, fair, reasonable, transparent in how they are determined and geographically appropriate. And all of the language that would clearly indicate these prices are reliable, as produced by a third-party with essentially no skin in the game, is how I interpret it. There was one document that I found, written by MultiPlan and posted on a trade group site, where they did mention that they allowed insurers to, what they said, set guardrails around the price that MultiPlan generates to make sure that the insurer does not pay above a reference rate. So does not pay above the rate that the insurer sets as the maximum.

TEDDY DOWNEY: But in terms of understanding how MultiPlan works, the way you learned about how MultiPlan actually worked was calling sources, reading all that testimony, and then also when MultiPlan did sort of acknowledge that on their website. But on that website, they didn’t say our prices are not fair or an independent anymore, did they?


VIKAS KUMAR: I was just going to add that a lot of these types of arguments were raised in the Ingenix dispute where, I guess, when people complained about low reimbursement rates, United would point to Ingenix as being independent research from across the health care industry without disclosing how the rates were set and maybe that the database wasn’t necessarily free from influence by outside parties.

TEDDY DOWNEY: And in terms of who is sort of allegedly harmed by these prices, these sort of manipulated price, we’ve got the health care providers. We’ve got the employers who pay for the health insurance. We’ve got the employees of the employers who get the health insurance and use the health insurance. How are these sort of customers in this supply chain harmed by the prices being manipulated? I know we’ve kind of gone through it a little bit, but I just want to kind of get it as explicit as I can from you.

LISA EPSTEIN: Okay. So that’s a great question. So the patients are obviously harmed because they have to pay more than they had planned for, more than they expected. As well as, people often choose a plan that affords them out of network health care benefits, which the insurance company will chip in a percent of what is assumed to be a fair payment rate for those out of network providers. And they pay a higher premium, sometimes significantly higher. And so they’re not getting the value of that premium, the true value of that premium. So patients are harmed in those ways.

Providers are obviously harmed because they are receiving payment that is much less than should be a fair and reasonable rate. And the administrative burden that often results in no change in the rate, but the administrative burden of trying to appeal these rates and even find out what happened, appeal them, try to get the correct reimbursement, work with the patient, who now does not understand why they owe $310 as opposed to one $160. So the administrative burden is immense from what the providers are telling me.

So MultiPlan says that—or they did in 2020—they said that about 78 percent of the claims that they processed, or the claim dollars that they processed, come from employer self-funded plans. So big employers, usually with a thousand employees or more or ones that operate in multiple states, will fund their own health care plan. They’ll pay the providers. They will issue the plans and design the plans the way that they see fit. And there’s multiple reasons. There’s tax benefits for that. There’s regulatory benefits for that for the employer.

So employers, let’s say Home Depot and your local grocery store that’s in multiple states, they don’t want to be administering the claims and dealing with patient calls and provider calls. So they hire typically a big insurance company to administer the health care plan. And then financial agreement is that the employer will pay a certain amount, let’s say $20 per employee per month, to the insurer to manage their health care plan. And then there’s all sorts of add on services. And one of the add on services is management of the cost of out of network claims.

And so the let’s say, UnitedHealth goes to the employer and says, hey, I’m going to make sure you pay less for out‑of-network claims. And in the fine print is I’m going to charge you 30 percent of however much I save you. So if the provider bills $400 and you have to end up paying only $200, we’re going to charge you 30 percent of the $200 that you saved.

So the insurer that’s the client of MultiPlan benefits more the lower the payment to the provider is compared to what the provider billed. The insurer charges a percentage of that to the employer. So they benefit. The bigger that difference is, the bigger the fee the insurer charges the employer. So then that’s the third-party that is being harmed by this practice.

TEDDY DOWNEY: Well, but in that case, the employer is saving money potentially, and the insurer and MultiPlan are incentivized to push the costs onto the patient.


TEDDY DOWNEY: Right. So but then the employer is harmed in that their employees are unhappy with their health care.

LISA EPSTEIN: That’s correct. And HR is fielding employee complaints. And they’re not saving anywhere near what’s promised to be saved, right?

TEDDY DOWNEY: Ostensibly, they designed the health care plan to be a good health care plan for their employees, not necessarily just to load more costs onto them. I mean, I don’t want to speak for all these employers. Some might like this, but I imagine it’s not really a zero-sum game if they’re saving money and their own employees are unhappy.


TEDDY DOWNEY: I don’t have any questions from the audience. I think the only thing that I would ask you guys is it seems like, as people find out that MultiPlan is not a fair and independent price, like Ingenix—I guess here’s the question. Do you see a lot of parallels between what’s going on with MultiPlan and Ingenix? I mean, it sounds very similar to what happened, what the insurers were doing with Ingenix. I mean, the history kind of fits a very kind of clean pattern. When Ingenix was around, they got cracked down on by the insurers had to go away from using Ingenix after Cuomo cracked down on them for five years. They had a settlement that seemed to work and there were fair prices. And then along comes MultiPlan to fill the Ingenix role. It just seems like there are a lot of parallels. Would you agree? Or what’s your take on the parallels?

VIKAS KUMAR: So I know the notion of like Ingenix 2.0 has certainly been floated. I think the one difference that they needed to make it so that it wasn’t as egregious or clearly as bad as Ingenix was create the appearance of having an independent third-party. Because one of the sticking points in Ingenix issue was that United owned Ingenix, which obviously then the conflict of interest is much stronger and easier to prove.

And here what they seem to be doing is having the appearance of an independent third-party in MultiPlan that is really subject to manipulation and control by the insurer. So that the end result is ultimately the same and that the incentives are aligned to push down the price to the harm of all the parties that Lisa and you discussed earlier.

TEDDY DOWNEY: So we do have one question from the audience. Which regulator would be responsible for looking into this alleged fact that—it would strike me clearly, the New York Attorney General seems to have a pretty clear potential role in enforcing both unfair and deceptive practices here, since they already did that—any other regulators or law enforcers who could weigh in here or that would be the sort of reasonable to expect they might be interested. Other state AGGs, FTC? What do you guys think?

VIKAS KUMAR: My understanding is—and I would need to double check this, obviously. But my understanding is almost every state has similar laws to the ones that are on the books that New York used to go after Ingenix in the past. And then obviously, to the extent there’s unfair and deceptive practices alleged, the federal regulator could certainly step in. There is a potential issue with insurance cases, but I’m not sure if that would necessarily apply here. And we’ve seen the FTC go after companies that have alleged improper practices, at least in connection with the sale of health insurance. But again, that’s something that I think we could give a little more thought to. But I think they probably have other thoughts as well.

LISA EPSTEIN: The CFPB just released a report on medical costs and bills, these bills and financial impact and the credit reporting impact of medical bills on consumers. Now, the CFPB does not have jurisdiction over insurance, but it’s possible that they might have either some role in helping to expose these practices or to the extent that the balance bill hits the patient and/or their credit report, there might be a role there for the CFPB. I don’t know enough about their jurisdiction and if they could intervene or enforce an enforcement action on this issue.

TEDDY DOWNEY: Yeah, it definitely does seem like since there is all this attention on surprised billing by recent laws passed, new regulation, to the extent that MultiPlan plays a role in increasing these numbers and ending up playing a role in the surprise billing problem, it would at least get some federal attention—and since this is a priority in the federal government. But obviously, there is state enforcement authority. So we’ll have to watch those.

LISA EPSTEIN: So there’s two other things. One, the Senate Commerce Committee held two hearings and issued a report on this issue back in 2009, and we linked to the testimony and the report in our article. And additionally, there is a role here, believe it or not, for the Department of Labor, which regulates the correct application of employer funded health plans. It’s a technicality, but there’s potentially a role for the Department of Labor here.

TEDDY DOWNEY: Very interesting, very interesting. And we’ve got some other questions here. I’ll say both at the same time as it sort of seems like the same question in some respects. Are there any other companies in this space other than MultiPlan? And are there are nonprofits that can fill this role, as they did in New York after Ingenix was shut down? Yeah, I guess is that New York Fair Health still even around? I’m curious. Any thoughts on these questions?

LISA EPSTEIN: Yes, Fair Health is still there. Anyone can Google Fair Health and put in any type of medical service and your zip code and up will come pricing that Fair Health generates based on the claims that are submitted by providers across the nation. And it will show you an out-of-network price and an in-network price and all other types of information related to the service that you’re looking up. So that is still in existence. It’s still nonprofit. It is still going strong.

TEDDY DOWNEY: So you could easily kind of envision a settlement again or an investigation and settlement where the insurers are compelled to start using Fair Health again. I mean, I’m not saying that—I don’t want to say, oh, is this likely to happen or not? But that would be a pretty obvious remedy potentially.

LISA EPSTEIN: It could be.

VIKAS KUMAR: Lisa, do you also want to briefly discuss how in some cases you could benchmark it publicly available data as well, the pricing?

LISA EPSTEIN: Well, yes. As I had explained, there are several different methodologies that MultiPlan allows or recommends insurers implement. As I said, you could do meet or beat pricing. You could set a max price. You could set a percentage of the Medicare rate. So, for instance, 500 percent of Medicare, 350 percent of Medicare. They could drop these rates and increase the rates, depending on whatever MultiPlan recommends or the insurer wishes to implement. So does that answer your question? There are multiple methodologies and one of them is to—go ahead.

VIKAS KUMAR: Yeah, I was just going to say that I think during the TeamHealth trial, one of the arguments that the lawyers for team health were making was that there wasn’t really anything unique or proprietary about the risk that MultiPlan was spitting out. It was just based on publicly available data. So if insurers wanted to provide transparency to their customers, even if they were forced to use a third-party, whatever the case would be, they could benchmark it to a publicly available dataset so that there wouldn’t be manipulation or anything like that. And that’s something we will potentially be exploring down the road.

TEDDY DOWNEY: But it doesn’t seem, I mean, and there are no like other companies that actually provide a standardized, fair price, are there? Or are their competitors to MultiPlan who can say, hey, we actually do this, but in a fair and independent way?

VIKAS KUMAR: So I’m not sure about the fair and independent way. One of the things that we encountered in our calls was people would be saying they used either Viant or Data iSight, without knowing that MultiPlan owns all of them. So obviously, MultiPlan has acquired some of its competitors. And so it’s not clear how much of a real competitive marketplace there is for these pricing tools outside of MultiPlan and some of the publicly available ones like Fair Health.

TEDDY DOWNEY: It also doesn’t really seem like a for profit model works, or at least a for profit model that they have here. Because even you all found evidence of the insurers setting the prices. But the incentive for MultiPlan and the insurers is to figure out—because they’re getting paid off of lowering the price—they have an incentive that’s kind of a built-in conflict of interest, a built‑in incentive to do this anyway, even if they weren’t caught red handed. It doesn’t seem like it would really ultimately ever be a fair, truly fair and independent, if you were going to have a similar model or competing model with those paid in a similar way. I mean, obviously, they could probably get paid—a different kind of model potentially could be for profit, but not something analogous, not something like what we have at this point. Is that a fair way to say it? Or did you think that was interesting in terms of the conflict there?

LISA EPSTEIN: Right. Well, both MultiPlan and its insurer customers make more money the wider the differences between the providers bill charge is and what’s paid to the provider. So the incentive is to either get providers to inflate their charges or pay the providers less or both.

TEDDY DOWNEY: Yeah, yeah. Last question here, and I think we’ll wrap up. Outside of an announcement from a state or federal regulator, is there anything to look out for to show this is something that is going to be investigated? So state or federal regulator, that sort of seems like Congress, I guess. I don’t know if that counts as a state or federal regulator. But litigation. What else? What else are you guys monitoring to see how this plays out? I mean, certainly, a lot of this is playing out in the courts because of some of the revelations. You write about in the piece clearly there is at least, as Lisa said earlier as well, that there’s a lot of litigation between these providers who all of a sudden are getting paid a lot less and their customers aren’t happy with them because they get tired of these big bills. Or the patients at least. So, courts. What else besides state and federal regulation? I mean, those seem like big ones, but anything else that we should be looking out for?

VIKAS KUMAR: No, I think those are sort of the big ones. The one thing I would say in a lot of the litigation, MultiPlan sometimes isn’t a party to the suit. And so evidence is sometimes introduced as happened in the TeamHealth case that directly implicates MultiPlan. And then what you’ll see is them come in and try to get a protective order to keep the evidence under seal.

And so sometimes the parties agree to certain conditions of protective orders. But at least in the case of TeamHealth, some of the evidence is going to come out, subject to redactions. So I think monitoring that type of stuff and seeing what else comes out from the evidence that can be in the public domain is something to keep an eye on. Because that may influence whether a regulator wants to take action or what else we can learn about how independent MultiPlan truly is or other practices that may be of concern.

LISA EPSTEIN: And it’s important to note that TeamHealth subsidiaries, in about, I think, seven, maybe eight other states, have filed similar lawsuits to the one that the Nevada subsidiaries filed. So there’s one in New York, Pennsylvania, Florida and several other states. So if these lawsuits go to trial and they’re naming insurers, not—I don’t think they name MultiPlan. I’d have to look and see. But these lawsuits are either going to settle or they’re going to end up going to trial. So if they go to trial, there’ll be more testimony and exhibits presented to further this story.

TEDDY DOWNEY: But in terms of a remedy, I mean, MultiPlan is really just a service provider for the insurers. And so the remedy ultimately, probably, at least if it’s going to mimic New York, it’s going to sort of compel the insurers to use a fair and independent price rather than a manipulated one, which is sort of the end game. But in terms of getting information, a lot of the lawsuits are saying the insurers themselves.

Yeah, I think the one point I would make, and maybe we can wrap things up, is it’s an interesting set of—it’s a big set of regulators, a big set of people who might be interested in this. You’ve got obviously the state AGs. You’ve got this rulemaking or surprise billing making its way through HHS. You’ve got the FTC potentially, if they can get around insurance exemptions or they’re not supposed to be looking at health insurers specifically. You’ve got the CFPB. to your point, looking at the debt collection when it comes to surprise billing and things like that. So you’ve got a lot of different avenues, and this is certainly a hot button issue when it comes to surprise billing.

And lastly, like you have this rare instance where the industry was successfully regulated for five years as a bit of a template, which seems somewhat rare, at least in sort of the history of looking at these types of things. So I think a lot of interesting things going on, a lot of interesting things for us to look at. And obviously, look forward to reading all your ongoing work on this, Lisa and Vikas. Thank you so much for doing this today.

LISA EPSTEIN: Thank you much, Teddy. It was a pleasure talking with you.

TEDDY DOWNEY: All right. Well, thanks to everyone for joining the call today, and this concludes the call.