Law360, New York ( June 13, 2014, 2:56 PM EDT) -- In today's health care system, reimbursement issues involve not only prompt pay statutory provisions but also various risk-shifting arrangements included in a delegated-network system of managed care. When the insolvency of an entity becomes an issue, state and federal courts have differed on whether health care insurers are responsible for payment of claims even when they contract with delegated entities that explicitly assume all payment responsibilities or when they have delegated that responsibility to medical providers as permitted by statute. Generally, the issue presented is whether a statutory scheme governing managed care and/or prompt payments preempts or limits common law claims. Most of the reported decisions involve reimbursement payment issues for emergency service providers. Historically, California appellate courts found that health maintenance organizations did not have a duty to make timely payments when an independent physician association failed to make payments nor did they have a duty to ensure the financial stability of the IPA.[1]...