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 .
DETAILED ACTION
Status of the Claims
The following office action in response to the application filed on 6/24/2024.
Claims 1-28 were previously presented.
Therefore, claims 1-28 are pending and addressed below.
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.
Claims 1-28 are rejected under 35 U.S.C. 101 because the claimed invention is directed to non-statutory subject matter.
Claims 1-28 are directed to a method, and a non-transitory computer readable medium and thus a statutory category of invention (Step 1: YES).
Claim 1 is rejected under 35 U.S.C. 101 because the claimed invention recites an abstract idea without significantly more. The claim recites the limitations of “…receiving a first record associated with a patient and the healthcare insurer during a previous time period; receiving a second record associated with the patient and the healthcare insurer during a current time period; and generating a notification to the patient to inform the patient of the enrollment lapse”. These recited limitations, as drafted, is a process that, under its broadest reasonable interpretation, covers performance of fundamental economic principles or practices (including insurance, i.e. detecting an enrollment lapse of health insurance for the patient) but for the recitation of generic computer components. If a claim limitation, under its broadest reasonable interpretation, covers concepts of fundamental economic principles or practices 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.
The additional limitations (besides those that recite the abstract idea) include the presence in the claimed method of a computer system, a database and one processor that are all recited at a high level of generality to perform the functions of “receiving …a first record; receiving… a second record; and generating…a notification to the patient to inform the patient of the enrollment lapse”, such that it amounts no more than mere instructions to apply the exception using a generic computer component. Accordingly, the additional elements do not integrate the abstract idea into a particular application because it does not impose any meaningful limits on practicing the abstract idea. The claim is directed to an abstract idea.
The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception or amount to an inventive concept. As discussed above with respect to integration of the abstract idea into a practical application, the additional limitations of the computer system, the database and the one processor that are all recited at a high level of generality to perform the functions of “receiving …a first record; receiving… a second record; and generating…a notification to the patient to inform the patient of the enrollment lapse”, above amounts to mere instructions to apply the exception using the generic computer component. When viewing the additional elements either individually or as an ordered combination, the claim as a whole does not amount to significantly more than the judicial exception because the claim does not include improvements to another technology or technical field, improvements to the function of the computer itself, and does not provide meaningful limitations beyond general linking the use of an abstract idea to a particular technological environment. In effect, the additional limitations add the words “apply it” (or an equivalent) to the judicial exception, or mere instructions to implement an abstract idea on a computer. Mere instructions to apply an exception using the generic computer component cannot provide an inventive concept. Thus, the claim is not patent eligible.
Independent claim 15 recite limitations substantially similar to claim 1. Thus, the claims are rejected based on the same reasoning as above in claim 1. Thus, the claims are not eligible.
Dependent claims 2-14 and 16-28 are dependent on claims 1 and 15. Therefore, claims 2-14 and 16-27 are directed to the same abstract idea of claims 1 and 15. Claims 2-14 and 16-27 further recite the limitations that merely refer back to further details of the abstract idea. In addition, the additional limitations (besides those that recite the abstract idea) of the user interface, the database and the computer included in the dependent claims 6, 7, 9, 17, 18, 20, 21, 23, 26, 28 that are all recited at a high level of generality to perform the functions of “…access…for the patient to provide enrollment data…to change their enrollment status…” (claim 6 and claim 20); “…provides …at least a portion of the enrollment data…” (claim 7 and claim 21); “performing …a first inquiry; and performing… a second inquiry…” (claim 9 and claim 23); “change… the current enrollment status of the patient…” (claim 17 and claim 18); “performing …an authentication with the database to validate…an authorization to perform queries” (claim 26); “generate …a second notification to inform medical provider of the enrollment lapse” (claim 28), such that it amounts no more than mere instructions to apply the exception using a generic computer component. 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. The claims are directed to an abstract idea.
The dependent claims 2-14 and 16-28 does/do not include additional elements that are sufficient to amount to significantly more than the judicial exception or amount to an inventive concept. As discussed above with respect to integration of the abstract idea into a practical application, the additional elements amount to nothing more than an instruction to “apply it” with the judicial exception. In addition, the additional limitations (besides those that recite the abstract idea) of the user interface, the database and the computer included in the dependent claims 6, 7, 9, 17, 18, 20, 21, 23, 26, 28 that are all recited at a high level of generality to perform the functions of “…access…for the patient to provide enrollment data…to change their enrollment status…” (claim 6 and claim 20); “…provides …at least a portion of the enrollment data…” (claim 7 and claim 21); “performing …a first inquiry; and performing… a second inquiry…” (claim 9 and claim 23); “change… the current enrollment status of the patient…” (claim 17 and claim 18); “performing …an authentication with the database to validate…an authorization to perform queries” (claim 26); “generate …a second notification to inform medical provider of the enrollment lapse” (claim 28), above amounts to mere instructions to apply the exception using the generic computer components. When viewing the additional elements either individually or as an ordered combination, the claim as a whole does not amount to significantly more than the judicial exception because the claim does not include improvements to another technology or technical field, improvements to the function of the computer itself, and does not provide meaningful limitations beyond general linking the use of an abstract idea to a particular technological environment. In effect, the additional limitations add the words “apply it” (or an equivalent) to the judicial exception, or mere instructions to implement an abstract idea on a computer. Mere instructions to apply an exception using the generic computer component cannot provide an inventive concept. Thus, when considering the combination of elements and the claimed as a whole, the dependent claims 2-14 and 16-28 are not patent eligible.
Conclusion
The prior art made of record and not relied upon is considered pertinent to applicant's disclosure.
Hallemeier et al. (10,991,457) teaches a method and a system related to healthcare coverage matching and verification. This method includes receiving, from a frontend graphical user interface (GUI), a healthcare coverage application comprising client demographics that include at least two of the following: a last name, a first name, a birthdate, an identification number, an address and a request type associated with a client, using a parallel matching and verification architecture to determine, based on a first set of criteria, a matching database record from an eligibility database that corresponds to the healthcare coverage application, and communicate with a healthcare provider using electronic data interchange transactions, identify, based on a second set of criteria, a medical policy that corresponds to the matching database record, and verify the medical policy, and transmitting, to the frontend GUI, the medical policy to allow reception of the medical policy by the client. Allen et al. (2021/0166322) teaches a method and a system related to performing certain actions, and/or adjusting insurance policies, or dynamic insurance or financial products, based upon (i) customer-related data indicative of risk, or lack thereof; (ii) changing insurance or financial needs; and/or (iii) life events, customer activity, or life circumstances. Biorge (2008/0059251) teaches a method and a system for managing a healthcare benefits plan based upon employee expenses and needs comprises an employee program that identifies, totals and or estimates employee expenses in communication with an employer computer and network, comprising enrollment modules configured to enable a plurality of employees with varying expenses to enroll in the healthcare benefit programs, using the employee expenses or estimates to determine the contributions and amounts of the benefit programs and periodically updating programs and contributions based upon the changing needs of employees. The system further comprises a processing center in communication with the network, the processing center comprising an accounting and reporting module configured to generate periodic statements regarding the usage of the healthcare benefits plan used for updating benefit programs. The system further comprises an issuing bank in communication with the network, the issuing bank being configured to establish a plurality of healthcare benefit accounts on behalf of the employees and to issue a healthcare benefit card to each employee. The employer computer comprises a benefit management module configured to monitor the performance of the healthcare benefits plan and adjust the contributions made to the healthcare benefits plan based on the periodic statements that identify the employee needs generated by the accounting and reporting module of the processing center.
Any inquiry concerning this communication or earlier communications from the examiner should be directed to Tien C. Nguyen whose telephone number is 571-270-5108. The examiner can normally be reached on Monday-Thursday (6am-2pm EST).
If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor,
Bennett Sigmond can be reached on 303-297-4411. The fax phone number for the organization where this application or proceeding is assigned is 571-270-6108.
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/TIEN C NGUYEN/ Primary Examiner, Art Unit 3694