AB 2415 amends California’s Health and Safety Code (Section 1371.55) and Insurance Code (Section 10126.65) to require parity in cost‑sharing for air ambulance care: when an enrollee, insured, or subscriber receives covered services from a noncontracting air ambulance provider, their out‑of‑pocket obligation is capped at the same cost‑sharing they would have paid for an in‑network provider.
The bill also requires the plan or insurer to inform both the enrollee/insured and the noncontracting provider of that in‑network cost‑sharing amount at the time the plan or insurer pays the provider, specifies that those payments count toward annual out‑of‑pocket limits and deductibles, restricts what a noncontracting provider can send to collections, and preserves existing Medi‑Cal balance‑billing protections. For compliance officers and billing teams, AB 2415 changes who can be billed, what must be communicated, and where payment disputes will be resolved.
At a Glance
What It Does
The bill mandates that covered air ambulance services provided by noncontracting providers carry no greater enrollee/insured cost‑sharing than an in‑network air ambulance; plans and insurers must notify both patient and provider of that amount when they make payment. It requires those patient payments to count toward out‑of‑pocket maximums and deductibles and limits collections activity to the capped amount.
Who It Affects
Applies to health care service plans regulated by the Department of Managed Health Care and health insurers regulated by the Department of Insurance, noncontracting air ambulance providers, enrollees/insureds/subscribers who receive air ambulance transport, and the billing/collections operations of providers and payers.
Why It Matters
Air ambulance transports produce some of the largest surprise bills; AB 2415 shifts the immediate financial burden off patients and onto payers and providers while leaving payment disputes unresolved by administrative rule—likely increasing negotiations and litigation and changing billing workflows.
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What This Bill Actually Does
AB 2415 targets one narrow but persistent source of surprise medical bills: air ambulance transports. For health plans (Health and Safety Code §1371.55) and for insurers (Insurance Code §10126.65), the bill requires that any enrollee or insured who receives covered air ambulance services from a noncontracting provider pay no more than the same cost‑sharing they would have paid for the identical service from an in‑network provider.
The statute names that ceiling the “in‑network cost‑sharing amount.”
The plan or insurer must communicate that in‑network cost‑sharing amount to both the enrollee/insured and the noncontracting provider at the time the plan or insurer pays the provider. Practically, this inserts a notification step into claims workflows: when the payer issues payment to an out‑of‑network air carrier, it must also specify the patient’s capped liability.
The bill treats any such patient payments as if they were made to an in‑network provider for purposes of annual out‑of‑pocket limits and deductibles, so patients do not lose credit for those payments.On collections and enforcement, the law bars noncontracting providers from pursuing more than the in‑network cost‑sharing amount in collections; that is the only amount they may advance to collections if the patient fails to pay. The statute leaves substantive payment disputes—how much the payer should pay the provider—out of administrative arbitration and expressly permits either side to seek relief in court.
Finally, the bill reiterates that Medi‑Cal beneficiaries remain protected under existing balance‑billing law (Welfare & Institutions Code §14019.4). The Insurance Code provisions mirror the Health & Safety Code rules so that both regulated plan and insurance markets follow the same patient‑protection and collections limits.
The Five Things You Need to Know
The bill applies to health care service plan contracts and health insurance policies issued, amended, or renewed on or after January 1, 2020.
When a payer pays a noncontracting air ambulance, the payer must inform both the enrollee/insured and the provider of the “in‑network cost‑sharing amount” at the time of payment.
Any cost‑sharing the patient pays for these air ambulance services must count toward the plan’s or policy’s annual out‑of‑pocket limit (Health & Safety §1367.006 / Ins. §10112.28) and be attributed to deductibles as if the service had been provided in‑network.
A noncontracting air ambulance provider may forward to collections only the in‑network cost‑sharing amount that the enrollee/insured failed to pay; it cannot balance‑bill the patient beyond that capped amount.
The statute permits providers and payers to resolve payment disputes in court and preserves Medi‑Cal’s separate balance‑billing protections under Welfare & Institutions Code §14019.4.
Section-by-Section Breakdown
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Enrollee cost‑sharing capped for noncontracting air ambulance providers
Subdivision (a) creates the core obligation for DMHC‑regulated plans: if an enrollee receives covered air ambulance services from a noncontracting provider, the enrollee owes no more than the in‑network cost‑sharing amount. The provision defines the in‑network cost‑sharing amount functionally (what the enrollee would pay in‑network) and assigns the plan the duty to determine and communicate that amount at the time it pays a noncontracting provider. That places claims‑processing and notification responsibilities squarely on the plan.
Counting payments toward out‑of‑pocket limits and deductibles
Subdivision (b) requires that any cost‑sharing the enrollee pays under this rule be counted toward the annual out‑of‑pocket maximum (per §1367.006) and be treated the same as if paid to a contracting provider for deductible accounting. For compliance teams, this means claims systems must apply patient payments from out‑of‑network air ambulance claims to the enrollee’s cost‑sharing accumulators the same way they would for in‑network claims.
Collections limits, dispute forum, and Medi‑Cal protection
Subdivision (c) caps what a noncontracting provider may send to collections—the in‑network cost‑sharing amount only. Subdivision (d) preserves the parties’ right to litigate payment disputes (the only explicit dispute forum the bill establishes) and clarifies providers may still use an existing plan’s internal dispute processes. Subdivision (e) notes air ambulance providers remain subject to Medi‑Cal balance‑billing protections under W&I §14019.4, preserving that separate regime for beneficiaries.
Parallel rule for insurers and insureds
This section mirrors the Health & Safety Code provisions for DOI‑regulated insurers: insureds/subscribers who receive covered services from noncontracting air ambulance providers are limited to the in‑network cost‑sharing amount, those payments count toward out‑of‑pocket limits and deductibles, payers must notify insureds and providers at payment, collections are limited to the capped amount, and either insurers or providers may go to court to resolve payment disputes. The duplicate structure ensures the rule applies consistently across the two regulatory regimes.
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Who Benefits
- Enrollees and insureds who use air ambulance services — they are protected from balance bills exceeding the in‑network cost‑sharing amount and retain credit toward out‑of‑pocket maximums and deductibles.
- Consumers with high emergency transport costs — the cap removes a frequent source of catastrophic, surprise medical bills tied to air transport.
- State regulators and consumer advocates — clearer statutory limits simplify enforcement messaging and consumer education about patient financial exposure in air transports.
Who Bears the Cost
- Noncontracting air ambulance providers — they lose the ability to directly bill patients above the capped cost‑sharing and may face collection shortfalls if payers and providers dispute the carrier’s full charge.
- Health plans and insurers — they must calculate and communicate the in‑network cost‑sharing amount when paying out‑of‑network providers and may shoulder higher payout obligations or litigation costs if disputes arise.
- Provider billing and collections vendors — their recoverable amounts from patients for air ambulance claims will shrink, requiring changes to billing scripts, collections practices, and dispute handling.
- Courts and litigants — the statute channels substantive payment conflicts into the judicial system, likely increasing litigation between payers and air ambulance providers over reimbursement levels.
Key Issues
The Core Tension
The bill resolves the immediate fairness problem for patients—preventing surprise air ambulance bills—by capping patient liability, but it leaves open who ultimately pays and how much, shifting the burden onto payers and providers; that trade‑off protects consumers while increasing negotiation and litigation over provider reimbursement, with no built‑in mechanism to both ensure timely adequate payment to providers and keep patients insulated.
AB 2415 tightly constrains what patients may be asked to pay, but it does not create a parallel mechanism for setting or enforcing the amount a payer must pay a noncontracting air ambulance provider. The statute places determination and notification duties on the plan or insurer and leaves substantive payment disagreements to be resolved in court.
That design avoids administrative rate‑setting but transfers the contested question—what constitutes fair payment for the ambulance service—into litigation and bilateral negotiation, with predictable costs for both sides.
Several operational ambiguities could complicate implementation. The statute requires the payer to “inform” the enrollee and provider of the in‑network cost‑sharing amount “at the time of payment,” but it does not define how that timing interacts with provisional payments, claim adjudication, or clawbacks.
The law also lacks an explicit enforcement penalty or an administrative dispute resolution path (binding arbitration or independent dispute resolution) for reimbursement disputes. Finally, although the bill preserves Medi‑Cal balance‑billing protections, it is silent about interplay with federally governed plans (for example, ERISA‑regulated self‑funded employer plans), which often raises preemption questions in this policy area.
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