"[A] California Court of Appeal ... agreed with a lower court decision granting summary judgment in favor of a payor by finding that the payor did not enter into a binding agreement with an out-of-network substance use treatment provider during a prior authorization and verification of benefits communication. The court's ruling has implications for out-of-network providers that rely on quasi-contractual theories to recover money from payors for services they rendered to members/insureds based on verification of benefits and prior authorization calls." [AToN Center, Inc. v. United Healthcare Ins. Co., No. D080122(Calif. Ct. App. Jul. 27, 2023)]

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