DETAILED ACTION
1. The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA . This Office action is in response to Applicant’s communication (RCE) filed on April 23, 2026. Amendments to claims 1, 8, and 15 have been entered. Claims 1-20 are pending and have been examined. The statement of reasons for the indication of allowable subject matter over prior art was already discussed in the Office action mailed on April 4, 2025 and hence not repeated here. The rejections and response to arguments are stated below.
Claim Rejections - 35 USC § 101
2. 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.
3. Claims 1-20 are rejected under 35 U.S.C. § 101 because the claimed invention is directed to an abstract idea without significantly more.
The claim(s) recite(s) a computer-implemented method for adjusting one or more electronic medical bills for a claimant injured in an accident, which is considered a judicial exception because it falls under the category of “Certain Methods of organizing human activity” such as fundamental economic practice as well as commercial or legal interactions including agreements as discussed below. This judicial exception is not integrated into a practical application as discussed below. The claim(s) does/do not include additional elements that are sufficient to amount to significantly more than the judicial exception as discussed below.
Analysis
Step 1: In the instant case, exemplary claim 15 is directed to a method.
Step 2A – Prong One: The limitations of “A computer-implemented method for adjusting one or more electronic medical bills for a claimant injured in an accident, the operations comprising:
training, by a processor of a management platform, a machine learning model with historical electronic medical bills and corresponding historical decisions made on the historical electronic medical bills based on a plurality of decisioning factors;
receiving, by the processor of the management platform, from an insurer system of an insurer through a network, an electronic medical bill comprising data representing medical services provided by a provider;
preprocessing, by the processor of the management platform, the received electronic medical bill, wherein preprocessing the received electronic bill comprises performing an input data transformation on the received electronic bill;
providing, by the processor of a management platform, the electronic medical bill as an inference input to the trained machine learning model;
selecting, by the processor of the management platform using the trained machine learning model, in response to the inference input, a workflow from a plurality of the workflows defining further processing of the electronic medical bill based on data within the electronic medical bill and at least one of the plurality of decisioning factors of the trained machine learning model, the workflows including a provider network workflow and a provider negotiations workflow;
routing, by the processor of the management platform, the electronic medical bill to a provider network system, wherein the provider network system adjusts the electronic medical bill by adjusting one or more payment amounts in the electronic medical bill according to agreed-upon network rates;
receiving, by the processor of the management platform, from the provider network system, the adjusted electronic medical bill; and
transmitting, by the processor of the management platform, the adjusted electronic medical bill to the insurer system” under the broadest reasonable interpretation, considered collectively as an ordered combination, covers methods of organizing human activity such as fundamental economic practice as well as commercial or legal interactions including agreements.
Adjusting one or more electronic medical bills for a claimant is fundamental economic practice such as processing insurance claims.
The steps of “providing, by the processor of a management platform, the electronic medical bill as an inference input to the trained machine learning model;
selecting, by the processor of the management platform using the trained machine learning model, in response to the inference input, a workflow from a plurality of the workflows defining further processing of the electronic medical bill based on data within the electronic medical bill and at least one of the plurality of decisioning factors of the trained machine learning model, the workflows including a provider network workflow and a provider negotiations workflow;
routing, by the processor of the management platform, the electronic medical bill to a provider network system, wherein the provider network system adjusts the electronic medical bill by adjusting one or more payment amounts in the electronic medical bill according to agreed-upon network rates;
receiving, by the processor of the management platform, from the provider network system, the adjusted electronic medical bill; and
transmitting, by the processor of the management platform, the adjusted electronic medical bill to the insurer system” under the broadest reasonable interpretation, considered collectively is a form of fulfilling agreements. Hence, the steps of the claim, considered collectively as an ordered combination without the italicized portions, covers the abstract category of “Certain Methods of organizing human activity”.
That is, other than, one or more hardware processors, a memory comprising instructions stored therein to perform the claimed operations, an insurer system of an insurer, a network, electronic medical bills, a trained machine learning model, the provider negotiations system and a provider network system, nothing in the claim precludes the steps from being performed as a method of organizing human activity. If the claim limitations, under the broadest reasonable interpretation, covers methods of organizing human activity but for the recitation of generic computer components, then it falls within the “Certain methods of organizing human activity” grouping of abstract ideas. Accordingly, the claim recites an abstract idea.
Step 2A – Prong Two: The judicial exception is not integrated into a practical application. In particular, the independent claims (1, 8 and 15) only recite the additional elements of one or more hardware processors, a memory comprising instructions stored therein to perform the claimed operations, an insurer system of an insurer, a network, electronic medical bills, a trained machine learning model, a provider negotiations system and a provider network system to perform all the steps. A plain reading of Figures 1, 2 and 5 and associated description in at least paragraphs [0072] – [0086] reveals that the one or more hardware processors may be general purpose microprocessors. The memory comprising instructions stored therein is a generic memory suitably programmed to store the associated information/instructions. The insurer system of an insurer, the provider negotiations system and the provider network system are generic systems suitably programmed to perform the associated functions. The network is a generic network suitably programmed to communicate with the associated components. The trained machine learning model is broadly interpreted to include suitably programmed software to perform the associated functions. The electronic medical bills and one or more non-transitory machine-readable storage media are similarly interpreted to include suitably programmed generic computer components. Hence, the additional elements in the claims are all generic components suitably programmed to perform their respective functions. The additional elements in all the steps are recited at a high-level of generality (i.e., as generic computer components performing generic computer functions) such that it amounts no more than mere instructions to apply the exception using generic computer components. Accordingly, these additional elements do not integrate the abstract idea into a practical application because they do not impose any meaningful limits on practicing the abstract idea. Hence, claims 1, 8 and 15 are directed to an abstract idea.
Step 2B: The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception. As discussed above with respect to integration of the abstract idea into a practical application, using the additional elements (identified above) to perform the claimed steps amounts to no more than mere instructions to apply the exception using a generic computer component. The additional elements of the instant underlying process, when taken in combination, together do not offer substantially more than the sum of the functions of the elements when each is taken alone. Mere instructions to apply an exception using a generic computer component cannot provide an inventive concept. Hence, independent claims 1, 8 and 15 are not patent eligible.
Dependent claims 2-7, 9-14 and 16-20, when analyzed as a whole are held to be patent ineligible under 35 U.S.C. 101 because the additional recited limitations only refine the abstract idea further.
For instance, in claims 2, 9 and 16, the steps “wherein the instructions further cause the one or more hardware processors to, responsive to selecting the provider negotiations workflow:
route the electronic medical bill to a provider negotiations process, wherein the provider negotiations process adjusts the electronic medical bill by adjusting one or more payment amounts in the electronic medical bill;
receive, from the provider negotiations system, through the network, the adjusted electronic medical bill; and
transmit the adjusted electronic medical bill to the insurer system through the network” under the broadest reasonable interpretation, are further refinements of methods of organizing human activity because these steps describe the intermediate steps of the underlying process.
In claims 3, 10 and 17, the steps “wherein the instructions further cause the one or more hardware processors to, prior to selecting a workflow:
retrieve, from a rules database, one or more rules established by the insurer; and
adjust the electronic medical bill according to the one or more rules” under the broadest reasonable interpretation, are further refinements of methods of organizing human activity because these steps describe the intermediate steps of the underlying process. The additional element of a rules database is broadly interpreted to correspond to generic database suitably programmed to store the associated rules. The additional element of the rules database, performs a traditional function recited at a high-level of generality such that it amounts no more than mere instructions to apply the exception using generic computer components.
In claims 4, 11 and 18, the steps “wherein the plurality of decisioning factors comprise at least one of:
a dollar value of charges in the electronic medical bill;
insurance policy coverage of the claimant;
expected turnaround time for processing the electronic medical bill; and
historical rates of success in provider negotiations for a type of electronic medical bill” under the broadest reasonable interpretation, are further refinements of methods of organizing human activity because these steps describe the data/information used in the intermediate steps of the underlying process.
In claims 5, 12 and 19 the steps “wherein the instructions further cause the one or more hardware processors to:
obtain a training data set comprising the historical electronic medical bills and corresponding historical decisions; and
train the machine learning model using the training data set” under the broadest reasonable interpretation, are further refinements of methods of organizing human activity because these steps describe the data/information used in the intermediate steps of the underlying process.
In claims 6, 13, and 20 the step “wherein the instructions further cause the one or more hardware processors to: generate the training data set” under the broadest reasonable interpretation, is a further refinement of methods of organizing human activity because this step describes an intermediate steps of the underlying process.
In claims 7 and 14, the steps “wherein the instructions further cause the one or more hardware processors to:
determine whether the electronic medical bill is eligible for further processing; and
select a workflow only responsive to determining the electronic medical bill is eligible for further processing” under the broadest reasonable interpretation, are further refinements of methods of organizing human activity because these steps further describe the intermediate steps of the underlying process.
In all the dependent claims, the judicial exception is not integrated into a practical application because the limitations are recited at a high-level of generality such that it amounts no more than mere instructions to apply the exception using generic computer components. Also, the claims do not affect an improvement to another technology or technical field; the claims do not amount to an improvement to the functioning of a computer system itself; the claims do not affect a transformation or reduction of a particular article to a different state or thing; and the claims do not move beyond a general link of the use of an abstract idea to a particular technological environment. In addition, the dependent claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception. The additional elements of the instant underlying process, when taken in combination, together do not offer substantially more than the sum of the functions of the elements when each is taken alone. The claims as a whole, do not amount to significantly more than the abstract idea itself. For these reasons, the dependent claims also are not patent eligible.
Response to Arguments
4. In response to Applicants arguments on page 9 of the Applicant’s remarks that the claims are patent-eligible under 35 USC 101 when considered under MPEP 2106, the Examiner respectfully disagrees.
The fact that the claims are Patent-Ineligible when considered under the MPEP 2106 has already been addressed in the rejection and the Applicant’s arguments have already been addressed in the rejection and hence not repeated here.
For these reasons and those discussed in the rejection, the rejections under 35 USC § 101 are maintained.
Conclusion
5. The prior art made of record and not relied upon is considered pertinent to applicant's disclosure:
(a) Patterson; Neal L. (US Patent 7881950 B2) discloses a method for adjudicating and reimbursing a care provider for services provided for a clinical event. The method includes the step of receiving a transaction having a number of clinical data elements. The method also includes the steps of accessing a data store including payer information and determining whether the transaction is eligible for reimbursement by at least one payer. The method also includes the steps of accessing a first knowledge base comprising evidence-based standards for providing medically appropriate care and selectively performing analysis of the clinical data elements of the transaction against at least one standard to determine if the care provided is medically appropriate. The method further includes the steps of accessing a second knowledge base containing at least one criterion for assessing quality of care and selectively performing analysis of the clinical data elements of the transaction against the at least one criterion to determine if the care provided is medically appropriate. Also, the method includes determining a level of reimbursement based on the medical appropriateness and quality of the care provided and authorizing reimbursement of the care provider from at least one payer.
6. Examiner interviews are available via telephone, in-person, and video conferencing using a USPTO supplied web-based collaboration tool. To schedule an interview, applicant is encouraged to use the USPTO Automated Interview Request (AIR) at http://www.uspto.gov/interviewpractice.
Any inquiry concerning this communication or earlier communications from the Examiner should be directed to Narayanswamy Subramanian whose telephone number is (571) 272-6751. The examiner can normally be reached Monday-Friday from 9:00 AM to 5:00 PM. If attempts to reach the examiner by telephone are unsuccessful, the examiner's supervisor, Abhishek Vyas can be reached at (571) 270-1836. The fax number for Formal or Official faxes and Draft to the Patent Office is (571) 273-8300.
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/Narayanswamy Subramanian/
Primary Examiner
Art Unit 3691
June 5, 2026
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