"Insurer Liability: Fraudulent Arbitration by HMO"

Engalla V. Permanente Medical Group, Inc., 938 P.2d 903 (Cal. 1997): "The court noted that an independent analysis revealed delays in 99 percent of all Kaiser medical malpractice arbitrations, including an average of 64 days for the appointment of a neutral arbitrator and 863 days to reach a hearing. the court noted, "there is evidence that Kaiser established a self-administered arbitration system in which delay for its own benefit and convenience was an inherent part, despite express and implied contractual representations to the contrary" (938 P .2d at 918). [Applebaum K L., Grudzinskas A J. J Am Acad Psychiatry Law, Vol. 26,No. 1, 1998: pp. 144-145]