From the article:
The common law fair procedure doctrine continues to serve health care providers well. As confirmed by the recent ruling in Palm Medical Group, Inc. v. State Compensation Insurance Fund (Ct.App. 1 Dist., March 25, 2008, #A114651), providers who are denied admission to the preferred provider networks of certain insurers without fair procedure can sue the insurers for money damages. This significantly levels the playing field for providers who seek admission to preferred provider networks.