"In other circuits, a health care provider, such as a physician, hospital or surgery center, could sue the insurer directly, provided the patient had signed an assignment of the right to payment from the insurer -- something a patient typically does when registering for treatment. But in the Third Circuit... courts were likely to rule that the assignment of the patient's right to payment wasn't sufficient to permit the provider to sue the insurer.... [On] September 11, 2015, ... [a] unanimous three-judge panel cited a combination of statutory law, case law and common sense in support of its conclusion that all a health care provider needs is an assignment of a right of payment in order to proceed against a health insurer." [North Jersey Brain & Spine Ctr. v. Aetna, No. 14-2101 (3d Cir. Sept. 11, 2015)]