DETAILED ACTION
Notice of Pre-AIA or AIA Status
The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA .
Notice to Applicant
Receipt of Applicant’s Amendment filed November 19, 2025 is acknowledged.
Response to Amendment
Claims 1-20 have been cancelled. Claim 21 has been added. Claim 21 is pending and is provided to be examined upon its merits.
Response to Arguments
Examiner acknowledges Applicant’s amendment and restoration of claim language to the originally elected invention. The amendments are compliant and is the claim is pending.
Claim Rejections - 35 USC § 101
35 U.S.C. 101 reads as follows:
Whoever invents or discovers any new and useful process, machine, manufacture, or composition of matter, or any new and useful improvement thereof, may obtain a patent therefor, subject to the conditions and requirements of this title.
Claim 21 is rejected under 35 U.S.C. 101 because the claimed invention is directed to a judicial exception (i.e., a law of nature, a natural phenomenon, or an abstract idea) without significantly more.
Subject Matter Eligibility Criteria – Step 1:
The claims recite subject matter within a statutory category as a process (claim 21). Accordingly, claims 21 is within at least one of the four statutory categories.
Subject Matter Eligibility Criteria – Step 2A – Prong One:
Regarding Prong One of Step 2A of the Alice/Mayo test, the claim limitations are to be analyzed to determine whether, under their broadest reasonable interpretation they “recite” a judicial exception or in other words whether a judicial exception is “set forth” or “described” in the claims. MPEP §2106.04(II)(A)(1). An “abstract idea” judicial exception is subject matter that falls within at least one of the following groupings: a) certain methods of organizing human activity, b) mental processes, and /or c) mathematical concepts. MPEP §2106.04(a).
The Examiner identifies method claim 21 as the claim that represents the claimed invention.
Claim 21:
A method for managing healthcare workflows, the method comprising:
obtaining healthcare data associated with a healthcare service from at least one external source;
analyzing the healthcare data;
providing an interface for viewing and managing the healthcare data;
receiving instructions from a user for performing an action; and
performing the action based on the instructions, the healthcare data, and the analysis.
These above limitations, not in bold, under their broadest reasonable interpretation, cover performance of the limitation as certain methods of organizing human activity. The claim elements are directed towards “viewing and managing healthcare data”, “receiving instructions from a user for performing an action”, and “performing the action based on the instructions”, which all describe managing personal behaviors of people.
These above limitations, under their broadest reasonable interpretation, also cover performance of the limitation as mental processes. The claims recite elements, underlined above, that can be performed in the mind of a person, with pen and paper, or using a generic computer. See also MPEP 2106.04(a)(2) III C that teaches generic computer performing an abstract idea can also fall under mental processes. These encompass receiving data, analyzing data, providing an interface, receiving instructions, and performing actions.
Accordingly, the claim recites an abstract idea.
Subject Matter Eligibility Criteria – Step 2A – Prong Two:
Regarding Prong Two of Step 2A of the Alice/Mayo test, it must be determined whether the claim as a whole integrates the idea into a practical application. As noted at MPEP §2106.04 (ID)(A)(2), it must be determined whether any additional elements in the claim beyond the abstract idea integrate the exception into a practical application in a manner that imposes a meaningful limit on the judicial exception. The courts have indicated that additional elements merely using a computer to implement an abstract idea, adding insignificant extra solution activity, or generally linking use of a judicial exception to a particular technological environment or field of use of a judicial exception to a particular technological environment or field of use do not integrate a judicial exception into a “practical application.” MPEP §2106.05(I)(A).
Examiner notes there are no additional elements recited in the independent claim. Though there are no additional elements recited in the claim as presently drafted, the specification makes it clear that Applicant intends the method to be performed electronically using some manner of computerized additional elements ([0013], “A system for managing healthcare workflows as a service (SaaS) includes: a computer communicatively coupled to a network, at least one SaaS provider, and at least one SaaS user. The computer is configured to obtain healthcare data associated with a healthcare service from at least one external source and to analyze the healthcare data.” [0014], “A computer-implemented method comprising instructions stored on a non-transitory computer-readable storage medium and executed on a computing device provided with a hardware processor and a memory for managing healthcare workflows via Software as a Service (SaaS).”). Accordingly, in the interest of compact prosecution, Examiner will evaluate the claim under Step 2A – Prong 2 and Step 2B as if the computerized additional elements noted above for receiving healthcare data are recited, as they were in the initial claim set provided on April 26, 2023.
The Examiner notes that the independent claims teach an insignificant extra-solution activity of receiving data. See also MPEP §2106.05(g).
The Examiner further notes that any and all computing devices (computer, computing device, and hardware processor) are taught at a high level of generality, such that it amounts to no more than mere instructions to apply the exception using any generic computing component. The Examiner cites [0049] of Applicant specification: “each computing device may be an Apple iPhone or iPad product, a Blackberry or Nokia product, a mobile product that executes the Android operating system, a personal computer, a tablet computer, a laptop computer and the like and the system is not limited to operate with any particular computing device.” No specific, technical improvements are being made to the technology of computing devices.
Storage devices (non-transitory computer-readable storage medium and memory) are also taught at a high level of generality. [0163] of Applicant specification recites: “The computer readable medium may be a computer readable signal medium or a computer readable storage medium (including, but not limited to, non-transitory computer readable storage media). A computer readable storage medium may be, for example, but not limited to, an electronic, magnetic, optical, electromagnetic, infrared, or semiconductor system, apparatus, or device, or any suitable combination of the foregoing. More specific examples (a non-exhaustive list) of the computer readable storage medium would include the following: an electrical connection having one or more wires, a portable computer diskette, a hard disk, a random access memory (RAM), a read-only memory (ROM), an erasable programmable read-only memory (EPROM or Flash memory), an optical fiber, a portable compact disc read-only memory (CD- ROM), an optical storage device, a magnetic storage device, or any suitable combination of the foregoing. In the context of this document, a computer readable storage medium may be any tangible medium that can contain, or store a program for use by or in connection with an instruction execution system, apparatus, or device.” As a wide variety of generic storage devices are utilized within the scope of the invention, no specific, technical improvements are made to storage devices.
The network is also taught at a high level of generality. [0166] of Applicant specification recites: “the remote computer may be connected to the user's computer through any type of network, including a local area network (LAN) or a wide area network (WAN), or the connection may be made to an external computer (for example, through the Internet using an Internet Service Provider).” As a variety of generic networks are simply utilized within the scope of the invention, no specific, technical improvements are made to networking technologies.
Thus, taken alone, the additional elements do not integrate the at least one abstract idea into a practical application.
Looking at the additional elements as an ordered combination adds nothing that is not already present when looking at the elements taken individually. For instance, there is no indication that the additional elements, when considered as a whole with the limitations reciting the at least one abstract idea, reflect an improvement in the functioning of a computer or an improvement to another technology or technical field, apply or use the above-noted judicial exception with a particular machine or manufacture that is integral to the claim, effect a transformation or reduction of a particular article to a different state or thing, or apply or use the judicial exception in some other meaningful way beyond generally linking the use of the judicial exception in some other meaningful way beyond generally linking the use of the judicial exception to a particular technological environment, such that the claim as a whole does not integrate the abstract idea into a practical application of the abstract idea. MPEP §2106.05(I)(A) and §2106.04(IID)(A)(2).
Subject Matter Eligibility Criteria – Step 2B:
Regarding Step 2B of the Alice/Mayo test, representative independent claims do not include additional elements (considered both individually and as an ordered combination) that are sufficient to amount to significantly more than the judicial exception for reasons the same as those discussed above with respect to determining that the claim does not integrate the abstract idea into a practical application.
These claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception. As discussed above with respect to discussion of integration of the abstract idea into a practical application, the additional elements amount to no more than mere instructions to apply an exception, add insignificant extra-solution activity to the abstract idea, and generally link the abstract idea to a particular technological environment or field use. Additionally, the additional limitations, other than the abstract idea per se, amount to no more than limitations which:
Amount to elements that have been recognized as activities in particular fields (such as Receiving or transmitting data over a network, e.g., using the Internet to gather data, Symantec, 838 F.3d at 1321, 120 USPQ2d at 1362 (utilizing an intermediary computer to forward information), MPEP §2106.05(d)(II)(i);storing and retrieving information in memory, Versata Dev. Group, MPEP §2106.05(d)(II)(iv)).
Looking at the limitations as an ordered combination adds nothing that is not already present when looking at the elements taken individually. There is no indication that the combination of elements improves the functioning of a computer or improves any other technology. Their collective functions merely provide conventional computer implementation.
Therefore, whether taken individually or as an ordered combination, claim 21 is nonetheless rejected under 35 U.S.C. 101 as being directed to non-statutory subject matter.
Claim Rejections - 35 USC § 102
The following is a quotation of the appropriate paragraphs of 35 U.S.C. 102 that form the basis for the rejections under this section made in this Office action:
A person shall be entitled to a patent unless –
(a)(1) the claimed invention was patented, described in a printed publication, or in public use, on sale, or otherwise available to the public before the effective filing date of the claimed invention.
Claim 21 is rejected under 35 U.S.C. 102(a)(1) as being anticipated by Basra (20200364801).
Regarding claim 21, Basra teaches a method for managing healthcare workflows, the method comprising:
obtaining healthcare data associated with a healthcare service from at least one external source ([0174], “claim data can be received into the computing system. This can include, for example, various claims made for health services and goods provided to patients by the healthcare organizations. Each patient claim may correspond to a particular insurance company for that patient, and each claim may include multiple claim items.”);
analyzing the healthcare data ([0037], “cause the contract ingestion engine to automatically process the first contract data file using optical character recognition, machine learning, and natural language processing; wherein the processing of the first contract data file includes parsing the first contract data file to identify a first set of medical procedure identifier parameters identifying a first medical procedure; wherein the processing of the first contract data file further includes parsing the first contract data file to identify a first set of contract payment rate parameters relating to the first medical procedure;” [0340], “FIG. 23, it is assumed that a user has used the system GUI to display a primary filters pop up box with different data fields to allow a user to search through a large number of claims” [0342], “Data fields on the further filters pop up box for FIG. 24 can include, for example, medical record number, claim status codes, total claim charge amounts, total claim payment amounts, and patient responsibility amounts.”);
providing an interface for viewing and managing the healthcare data ([0112], “Information filtering module(s) 349 which, for example, may be adapted to automatically and dynamically generate, using one or more filter parameters, filtered information to be displayed on one or more displays of the mobile device.” [0341], “In each of the specific embodiments of FIGS. 24-28, it is assumed that a user has used the system GUI to display a respective further filters pop up box with further data fields to allow a user to search through a large number of claims”);
receiving instructions from a user for performing an action ([0335], “FIG. 41, it is assumed that a user has used the system GUI to display a claims summary page for a given case. This can take place, for example, by a user selecting a “Cases” tab at a top selection bar within the GUI and then selecting “Claims” for a selected case from a drop down menu. Alternatively, the user can input a keyboard shortcut to arrive at the same claims summary page for a given case. Data and information on this GUI page can include, for example, a claim number, status, hospital name, payer name, billed amount, collected amount, and extended base price.” [0359], “FIG. 45, it is assumed that a user has used the system GUI to display an appeals page for a given case. This can take place, for example, by a user selecting a “Cases” tab at a top selection bar within the GUI and then selecting “Appeals” for a selected case from a drop down menu. Alternatively, the user can input a keyboard shortcut to arrive at the same case appeals page. A regular user accessing this GUI page can select a Create Appeals button to automatically generate prefilled appeal forms for all of the claims in a case for appeals processing and correspondence.”); and
performing the action based on the instructions, the healthcare data, and the analysis ([0035], “transaction analysis and asset recovery systems and methods can include various specialized engines that can rapidly normalize, parse, analyze, and provide reports on massive amounts of data from many sources and in a wide variety of different original formats.” [0359], “A regular user accessing this GUI page can select a Create Appeals button to automatically generate prefilled appeal forms for all of the claims in a case for appeals processing and correspondence.”).
Conclusion
Applicant's amendment necessitated the new ground(s) of rejection presented in this Office action. Accordingly, THIS ACTION IS MADE FINAL. See MPEP § 706.07(a). Applicant is reminded of the extension of time policy as set forth in 37 CFR 1.136(a).
A shortened statutory period for reply to this final action is set to expire THREE MONTHS from the mailing date of this action. In the event a first reply is filed within TWO MONTHS of the mailing date of this final action and the advisory action is not mailed until after the end of the THREE-MONTH shortened statutory period, then the shortened statutory period will expire on the date the advisory action is mailed, and any nonprovisional extension fee (37 CFR 1.17(a)) pursuant to 37 CFR 1.136(a) will be calculated from the mailing date of the advisory action. In no event, however, will the statutory period for reply expire later than SIX MONTHS from the mailing date of this final action.
Any inquiry concerning this communication or earlier communications from the examiner should be directed to DAVID CHOI whose telephone number is (571)272-3931. The examiner can normally be reached M-Th:7:30-5:30 ET.
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If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Shahid Merchant can be reached on (571)270-1360. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300.
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/D.C./Examiner, Art Unit 3684
/Shahid Merchant/Supervisory Patent Examiner, Art Unit 3684