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EXHIBIT 3

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IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF DELAWARE

MCKESSON INFORMATION SOLUTIONS LLC, ) ) Plaintiff, ) ) V. ) ) THE TRIZETTO GROUP, INC., ) ) Defendant. )
____________________________________________________________________________________)

CiVIL ACTION NO. 04-1258-SLR

PLAINTIFF MCKESSON'S SIXTH SUPPLEMENTAL RESPONSES TO DEFENDANT TRIZETTO'S FIRST SET OF INTERROGATORIES (1-20)
Plaintiff, McKesson Information Solutions LLC ("McKesson") hereby supplements its response as follows to Interrogatory No. 2 of the First Set of Interrogatories by defendant, The TriZetto Group, Inc. ("TriZetto").

GENERAL OBJECTIONS
McKesson incorporates by reference as if fully set forth herein the General Objections set forth in its January 13, 2005 Responses to TriZetto's First Set of Interrogatories (1-20), its February 18, 2005 Supplemental Responses to Defendant TriZetto's First Set of Interrogatories

(1-20), its March 18, 2005 Second Supplemental Responses to Defendant TriZetto's First Set of
Interrogatories (1-20), its April 20, 2005 Third Supplemental Responses to Defendant TriZetto's First Set of Interrogatories (1-20), its June 13, 2005 Fourth Supplemental Responses to

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Defendant TriZetto's First Set of Interrogatories (1-20), and its September 15, 2005 Fifth Supplemental Responses to Defendant TriZettq's First Set of Jnterrogatories (1-20).

SUPPLEMENTAL RESPONSES

INTERROGATORY NO.2:
Describe in detail how each asserted claim of the '164 PATENT has been infringed by TRIZETTO (including, for each system or product accused of being infringed, stating in detail, by means of a claim chart, YOUR contention as to where each limitation of the asserted claim is found in the accused infringing TRIZETTO system or product and whether YOU are asserting literal infringement or infringement under the doctrine of equivalents).

SUPPLEMENTAL RESPONSE TO INTERROGATORY NO.2:
McKesson incorporates by reference as if fully set forth herein all prior responses to this

interrogatory, including objections. Subject to and without waiving the foregoing objections,
McKesson supplements its response to this interrogatory as follows:

Based on the information and documents currently available, including TriZetto's
document production in this case and the recent deposition testimony of TriZetto's employees, corporate witnesses, and customers, McKesson provides the claim chart attached hereto showing

TriZetto's known and admitted infringement of claims 1,2, 3,4, 5,6, 8,9, 10, 11, 12, 13, 14, 15
and 16 of the '164 patent based on the manufacture, use, sale, and offer for sale of ClaimFacts,
Facets and QicLink.

McKesson's investigation is continuing, including its ongoing depositions of TriZetto's
employees and corporate witnesses, its review of product manuals and other documentation that TriZetto failed to produce until shortly before the close of fact discovery, and its analysis of the
accused products -- of which TriZetto still has not provided complete working copies andlor

sufficient instructions to enable to proper installation and operation of those products.
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McKesson reserves the right to supplement this response as its investigation continues or as circumstances otherwise warrant.

DATED: September 21, 2005

By: __________
Jeffrey G. Randall
SKADDEN, ARPS, SLATE, MEAGHER & FLOM LLP

525 University Avenue, Suite 1100 Palo Alto, CA 94301

Attorneys for Plaintiff McKesson Information Solutions LLC

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PROOF OF SERVICE (FRCP 5)
I am a citizen of the United States and a resident of the State of California. I am
employed in Santa Clara County, State of California, in the office of a member admitted pro hac

to the bar of this Court, at whose direction the service was made. I am over the age of eighteen

years, and not a party to the within action. My business address is 525 University Avenue, Suite
1100, Palo Alto, CA 94301.

On September 21, 2005, I served PLAINTIFF MCKESSON'S SIXTH

SUPPLEMENTAL RESPONSES TO DEFENDANT TRIZETTO'S FIRST SET OF
INTERROGATORIES (1-20) in the manner described below:

(BY ELECTRONIC MAIL) I am personally and readily familiar with the
business practice of Skadden, Arps, Slate, Meagher & Flom LLP for collection

and processing of document(s) to be transmitted by electronic mail, and I
caused such document(s) on this date to be transmitted by electronic mail to the offices of addressee(s) at the numbers listed below.

and

(BY U.S. MAIL) I am personally and readily familiar with the business practice of Skadden, Arps, Slate, Meagher & Flom LLP for collection and
processing of correspondence for mailing with the United States Postal Service, and I caused such envelope(s) with postage thereon fully prepaid to be placed in the United States Postal Service at Palo Alto, California.
on the following parties in this action: Jeffrey Thomas, Esq. Gibson, Dunn & Crutcher LLP Jamboree Center 4 Park Plaza, Suite 1400 Irvine, CA 92614-8557 Facsimile: (949) 475-4670 Jack B. Blumenfeld, Esq. Morris, Nichols, Arsht & Tunnell 1201 N. Market Street P.O. Box 1347 Wilmington, DE 19899 Facsimile: (302) 425-3012

Executed on September 21, 2005 in Palo Alto, California.

Lindsay Coleman
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McKesson v. TriZetto INFRINGEMENT CLAIM CHART
1. In a computer systemhaving means for operating on a predetermined database containing medical service codes and a set of relationships among the medical service codes defming whether selected ones of the medical service codes are valid when input with other selected ones of the medical service codes, a method for processing input claims containing at least one medical service code, comprising the steps of:

Erisco's Facets and Healthweb at MCK 002352 (figure with "Facets Client" connected to "DBMS") Facets Product Overview (Spr 1996) at MCK 002312 ("Facets uses ... the client/server platform, which links individual personal computers to high performance relational database servers Facets Product Overview (Spr 1996) at MCK 002319 ("Clinical Edits Every claim you process is automatically edited by Erisco's proprietary clinical editing software, with tens of thousands of clinical rules and recommendations. ... Facets clinical editing clearly identifies potential problems, such as unbundled surgical procedures, claims billedincorrectly due to coding errors, unacceptable procedures and potentiallyfraudulent information. It also checks for invalid data relationships (like an inconsistency between diagnosis and procedure codes) and patterns of outpatient and inpatient utilization that deviate from the accepted standards

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Erisco ClaimFacts Marketing Brochure at TRZ 032141 ("You can implement ClaimFacts in one of two ways,... You can either implement the software at your site, or subscribe to remote service. . . . Ifyou choose to license ClaimFacts, our professional support staff will work with you to implement the system on your IBM or equivalent hardware.")

TriZetto Product Announcement: Introduction of ClinicaLogic Module in QicLink (March2002) at TRZ 277700-01 ("Since the claim editing logic is embedded within the [QicLink] Claims Adjudication program. .

Id. at TRZ 032143 ("IntelligentProcessing... ClinicaLogic is backedby an expert staff of board-certified physicians. Their combined clinical experience forms an expertknowledge database, updatedregularly as medicalcriteria change.")

Id. at TRZ 277700 ("the medicaldatabasethat forms the core of ClinicaLogic.. . [biased on [] collective medical knowledge and extensive claim checking experience [contains] over 90,000 clinical rules for claim checking. These rules apply to surgical, laboratory, radiological, anesthesia and other medical procedures as well as to diagnoses.")

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of clinical practice.")

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Erisco Facets Overview (webpage) at MCK 002308 ("Clinical Claims Audit Facets automatically edits every claim that you process with Erisco 'sproprietary clinical editingsoftware, with tens ofthousands of clinical rules and recommendations. This allows you to identify billingproblems and eliminate significant overpayment of claims, and to consistently catch fraudulent, erroneous or inconsistent billing practices, a significant factor in cost containment.") Facets Product Overview (Spr 1996) at MCK 002316 ("Claims Processing ... Claims processing utilizes diagnosis codes and procedure codes to read service based rules ....") M*Plan ProviderPerspective (Spr 2004) at MCK 002355 ("the PACE clinical editing system ... willencompass a comprehensive set of clinical claims editing criteria that will allow for the

Erisco ClinicaLogic Marketing Brochure (targeted at ClaimFacts customers) at MCK 034224 ("An Expert Knowledge-based System... ClinicaLogic is backed by a staff of board-certified physicians [whose] expertise forms the medical logic and review criteria database, the core of ClinicaLogic. This expert knowledge database is updated regularly as medical criteria change, making ClinicaLogic the

30(b)(6) deposition of John Danza

most comprehensive claims editor available today.")

ClaimFacts ClinicaLogic System Overview (January 2004) at TRZ 092356 ("Team of Specialists the medical database that forms the core of ClinicaLogic [has] over 90,000 clinical rules for claim checking. These rules apply to surgical, laboratory, radiological, anesthesia and other medical procedures as well as to diagnoses. Eachrule for a procedure includes medical data that indicate either an appropriate way to adjudicate the procedure or a proper relationship between the procedure and information such as the patient's age and sex.")

30b)(6) deposition of Karen Lampe
Deposition of Harrington Benefits

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evaluation ofmedical billing information and CPT coding

accuracy.t)
Deposition of Providence Health Plan receiving at least one claim; Facets Product Overview (Spr 1996) at MCK 002316 ("Claims Entry Claims can be entered online or electronically via proprietary format or the industry standard ..."). M*Plan Provider Perspective (Spr 2004) at MCK 002355 ("the PACE clinical editing system ... willbe implemented on claims with dates of service beginning May 1, 2004") Deposition ofProvidence HealthPlan Erisco Facets Overview (webpage) at MCK 002308 ("Clinical Claims Audit Facets automatically edits every claim that you process with Erisco's proprietary clinical editing software ....")

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Erisco ClaimFacts TriZetto Product Announcement: Introduction of Marketing Brochure at TRZ032143 ("Intelligent Processing... Clinical Logic is ClaimFacts' ClinicaLogic Module in OicLink (March 2002) at TRZ 277699 ("ClinicaLogic is a comprehensive, knowledgeintegrated medical claim editor. It automatically examines each claim instantly on-line, as it is processed.") basedmodule designed to automatically check medical claims before payment. ClincaLogic. . . checks claims as they are entered manually on-line or in batchmode. . ("Duplicate work is eliminated because you only have to enter date once. ClainiFacts automatically captures and stores original and medical edit information as it is entered on-line.") ClinicaLogic User Guide (2004) at TRZ 154738 ("ClinicaLogic runs seamlessly with QicLink claim processing by verifying claim data as it is entered.")

...

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Erisco ClinicaLogic Marketing Brochure (targeted at ClaimFacts customers) at MCK 034224 ("A Flexible, Integrated Solution.. . With ClinicaLogic you can screen existing claims data instantlyas they are entered online or batch-processed. . . . How ClinicaLogic Works When a claim is entered, ClinicaLogic compares. .

30(b)(6) deposition of John Danza

30(b)(6) deposition ofKarenLampe Deposition of Harrington Benefits

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determining whether any

medicalservice code contained in the at least one claim is not
present in the predetermined database; and informing a user that a medical service code is not contained in the predetermined database. M*Plan Provider Perspective (Spr 2004) at MCK002355 ("the PACE clinical editing system also cliecksfor ... outdated or Facets Product Overview (Spr 1996) at MCK 002319 ("Clinical Edits ... Facets clinical editing clearly identifies potential problems, such as unbundled surgicalprocedures, claims billed incorrectly due to coding errors, unacceptable procedures and potentially fraudulent information. ...")

Erisco Facets Overview at MCK 002308 ("Clinical Claims Audit ... This allowsyou to identify billing problems and eliminate significant overpayment of claims, and to consistently catchfraudulent, erroneous or inconsistent billing practices, a significant factor in cost containment.")

Erisco ClaimFacts Marketing Brochure at TRZ 032143 ("Intelligent Processing... ClinicaLogic warns you of questionable provider fees beforedisbursement. And it corrects "unbundling," unacceptable procedures, coding errors and more. It even checks for inadvertent or potentially fraudulent deviations from accepted clinical standards.")

TriZetto Product Announcement: Introduction of ClinicaLogic Module in QicLink (March 2002) at TRZ 277699 ("ClinicaLogic.. . checks claims as they are entered manually on-line or in batchmode.. . to CPT/HCPCS procedure coding errors.") identify:

...

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invalid codes")
Deposition of Providence Health Plan

Erisco ClinicaLogic Marketing Brochure (targeted at ClaimFacts customers) at MCK 034224 ("[ClinicaLogic] corrects 'unbundling,' unacceptable procedures and incorrectly billed claims due to coding errors or invalid data relationships. And it checks for inadvertent or potentially fraudulent deviations from generally accepted standards of clinical practice.")

30(b)(6) deposition of John Danza

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ClaimFacts ClinicaLogic System Overview (January 2004) at TRZ 092354-55 ("ClaimFacts ClinicaLogic Subsystem [ClinicaLogic] checks claims as they are entered on-line or in batch mode to identify: .. . CPT/HCPCS procedure coding

errors.")
30(b)(6) deposition of Karen Lampe Deposition of Harrington Benefits

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2. In a computer systemhaving means for operating on a predetermined database containing medical service codes and
Facets Product Overview (Spr 1996) at MCKOO23 12 ("Facets uses ... the client/server platform, which links individual personal computers to high performance relational database servers ....").
Facets Product Overview (Spr 1996) at MCK 002319 ("Clinical Edits Everyclaim you process is automatically edited by Erisco's proprietary clinical editing software, with tens of thousands of clinical rules and recommendations. ... Facets clinical editing clearly identifies potential problems, such as unbundled surgical procedures, claims billed incorrectly due to coding errors, unacceptable procedures and potentially fraudulent information. It also checks for invalid data relationships (like an inconsistency between diagnosis and procedure codes) and patterns of outpatient and inpatient utilization that deviate from the accepted standards

Erisco's Facets and Healthweb at MCK 002352 (figure with "Facets Client" connected to "DBMS"

Erisco ClaimFacts Marketing Brochure at TRZ032141 ("You can implement ClainiFacts in one oftwo ways, You can either implement the software at your site, or subscribe to remote service. . . . you choose to license ClaimFacts, our professional support staff will work with you to implement the systemon your IBM or equivalent hardware.")

If

TriZetto ProductAnnouncement: Introduction of ClinicaLogic Module in QicLink (March 2002) at TRZ 277700-0 1 ("Since the claim editing logic is embedded within the [QicLink] Claims Adjudication program. .

·1

a set of
relationships among the medical service codes defming whether selected ones of the medical service codes are valid when input with other selected ones ofthe medical service codes, a method for processing input claims containing at least one medical service code, comprising the steps of:

ji

at TRZ 032143 ("IntelligentProcessing... ClinicaLogic is backedby an expert staff ofboard-certified physicians. Their combined clinical experience forms an expert-knowledge database, updated regularly as medical criteria change.")

Id. at TRZ277700 ("the medicaldatabasethat forms the core of ClinicaLogic. . . [biased on [] collective medical knowledge and extensive claim checking experience [contains] over 90,000 clinical rules for claim checking. These rules apply to surgical, laboratory, radiological, anesthesia and other medical procedures as well as to diagnoses.")

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of clinical practice.")

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Erisco Facets Overview (webpage) at MCK 002308 ("Clinical Claims Audit Facets automatically edits every claim that you process with Erisco's proprietary clinicalediting software, with tens ofthousandsofclinical rules and recommendations. This allows you to identify billing problems and eliminate significant overpayment of claims, and to consistently catch fraudulent, erroneous or inconsistent billingpractices, a significant factor in cost containment.") Facets Product Overview (Spr 1996) at MCK 002316 ("Claims Processing ... Claims processingutilizes diagnosis codes and procedure codes to read service based rules ....") M*Plan ProviderPerspective (Spr 2004) at MCK 002355 ("the PACE clinical editing system ... will encompass a comprehensive set of clinical claims editing criteria that will allow for the evaluation ofmedicalbilling information and CPT coding accuracy.")

Erisco ClmicaLogic Marketing Brochure (targeted at ClainiFacts customers) at MCK 034224 ("An Expert Knowledge-based System... ClinicaLogic is backedby a staff of board-certified physicians [whose] expertise forms the medical logicand review criteria database, the core of ClinicaLogic. This expertknowledge database is updated regularly as medical criteria change, making ClinicaLogic the most comprehensive claims editor available today.")

30(b)(6) deposition of John Danza

ClaimFacts ClinicaLogic System Overview (January 2004) at TRZ 092356 ("Team of Specialists the medical database that forms the core of ClimcaLogic [has] over 90,000 clinical rules for claim checking. These rules apply to surgical, laboratory, radiological, anesthesia and other medical procedures as well as to diagnoses. Eachrule for a procedure includes medical data that indicate either an appropriate way to adjudicate the procedure or a proper relationship between the procedure and information such as the patient's age and sex.") 30(b)(6) deposition of KarenLampe Deposition of Harrington Benefits

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Deposition ofProvidence Health Plan receiving at least one claim; Erisco Facets Overview (webpage) at MCK 002308 ('Clinical Claims Audit Facets automatically edits every claim that you process with Erisco's proprietary clinical editing software .
Facets Product Overview (Spr 1996) at MCK002316 ("Claims Entry Claims can be entered online or electronically via proprietary format or the industry standard ...").

Erisco ClaimFacts Marketing Brochure at TRZ 032143 ("Intelligent Processing... Clinical Logic is ClaimFacts' integrated medical claim editor. It automatically examines each claim instantly on-line, as it is processed.")

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M*Plan ProviderPerspective (Spr 2004) at MCK 002355 ("the PACE clinical editing system ... willbe implemented on claims with dates ofservice beginning May 1, 2004") Deposition ofProvidence Health Plan

jçj. ("Duplicate work is eliminated because you only have to enter date once. ClaimFacts automatically captures and stores original and medical edit information as it is entered on-line.")

TriZetto Product Announcement: Introduction of ClinicaLogic Module in OicLink (March 2002) at TRZ 277699 ("ClinicaLogic is a comprehensive, knowledgebased module designed to automatically check medical claims before payment.... ClincaLogic. . . checks claims as they are entered manually on-line or in batch mode. .

Erisco ClinicaLogic Marketing Brochure (targeted at ClaimFacts customers) at MCK034224 ("A Flexible, Integrated Solution. . . With ClinicaLogicyou can screen existing claims data instantly as they are entered online or batch-processed. . . . How ClinicaLogic Works When a claim is entered, ClinicaLogic compares . .

ClinicaLogicUser Guide (2004) at TRZ 154738 ("ClinicaLogic runs seamlessly with QicLink claim processing by verifying claim data as it is entered.")

30(b)(6) deposition ofJohnDanza

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ClaimFacts ClinicaLogic System Overview (January 2004) at TRZ 092364 ("How ClinicaLogic Operates Claims entered to ClaimFacts are first examined. .

30(b)(6) deposition of Karen Lampe Deposition of Harrington Benefits ascertaining whether the at least one claim contains a plurality of medical service codes; M*Plan Provider Perspective (Spr 2004) at MCK 002355 ("The PACE clinical editing system is designedto detect ... Unbundling/Rebundling -- Billing under several CPT codes ....") Facets Product Overview (Spr 1996) at MCK 002319 ("Clinical Edits Facets clinical editing clearly identifies potential problems, such as unbundled surgicalprocedures ....") Deposition of Providence HealthPlan M*Plan Provider Perspective (Spr 2004) at MCK 002355 ("The PACE clinical editing system is designedto detect irregularities in

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Erisco ClinicaLogic Marketing Brochure (targeted at ClaimFacts customers) at MCK 004812 ("When a claim is entered, ClinicaLogic compares procedure codes from multiple services, flagging potential problems.") 30(b)(6) deposition of Karen Lampe Deposition of Harrington Benefits

TriZetto Product Announcement: Introduction of ClimcaLogic Module in QicLink (March 2002) at TRZ 277699 ("ClinicaLogic.. . checks claims as they are entered manually on-line or in batch mode.. . to identify: "unbundled" procedures (i.e., procedures covered by one comprehensive CPT!HCPCS procedure code that are itemized on the provider's bill, possiblyresulting in an overstatement of charges).")

30(b)(6) deposition of JohnDanza determining whether one ofthe

ClaimFacts ClinicaLogic System Overview (January 2004)

at TRZ 092354-55 ("ClaimFacts ClinicaLogic Subsystem

TriZetto Product Announcement: Introduction of ClinicaLogic Module in OicLink (March 2002) at TRZ

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medical service codes in the at least one claim is mutuallyexclusive due to nonmedical criteria with any other medicalservice code in the at least one claim;

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medical billings, such as: ... Mutually Exclusive/Redundant Procedures-- Defined asthe billing of two or more procedures that, by medicalpractice standards, would not be billed on the same date of service. ... the PACE clinical editing system also checks for ... assistant surgeon eligibility ... and appropriateness

of... place of service."")

Facets Product Overview (Spr 1996) at MCK002319 ("Clinical Edits ... Facets clinical editing ... checks for ... patterns of outpatient and inpatient utilization that deviate from accepted standards of clinical practice.") Deposition of Providence Health Plan

[ClinicaLogicj checks claims as they are entered on-line or in batchmode to identify: . . . CPT/HCPCS procedure coding errors or invalid data relationship (e.g., the procedure is inconsistent with the patient's sex; . . . patterns of outpatient and inpatient utilization deviation from common standards of clinical practice;. . . diagnoses that may be inappropriate for the sex and/or age of the patient, or that may require case management.") 30(b)(6) deposition ofKarenLampe Deposition of Harrington Benefits

277699 ("ClinicaLogic. . . checks claims as they are entered manually on-line or in batch mode. . . to identify: . . . CPT/HCPCS procedure coding errors or invalid data relationships (e.g., the procedure is inconsistent with the patient's sex);.. . paterns of outpatient and inpatient utilization deviating from common standards of clinical practice; . . . diagnosesthat maybe inappropriate for the sex and/or age of the patient that may require case management.")

30(b)(6) deposition of JohnDanza

authorizing medical service

codes which are not mutually
exclusive due to non-medical criteria with any other medical service codes contained in the at least one claim in response to the determining step; and Deposition of Providence Health Plan

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Erisco Facets Overview at MCK 002308 ("ClinicalClaims Audit Facets automaticallyedits every claim that you process with Erisco's proprietary clinical editing software, with tens of thousands ofclinical rules and recommendations. This allows you to identify billing problemsand eliminatesignificant overpayment ofclaims, and to consistently catch fraudulent, erroneous or inconsistent billing practices, a significant factor in cost containment.")

Erisco ClinicaLogic Marketing Brochure (targeted at ClaimFacts customers) at MCK 034224 ("How ClinicaLogic Works. . . As ClinicaLogicdetects inconsistencies online, it displays clear instructions on the Claims Processing Screen, enablingthe examiner to make appropriatedecisions. An edit may be acceptedor overridden, or the original claim maybe pended for review.")

TriZetto Product Announcement: Introduction of ClinicaLogic Module in OicLink (March 2002) at TRZ 277700 ("Some edits detect and, in certain situations, automatically correct commonly encountered coding errors. Other edits identify potential improprieties regarding claim procedures and diagnoses. ClinicaLogic's flexibility allows

the user to utilize any or all of the edits. . .

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ClaimFacts ClinicaLogic System Overview (January 2004) at TRZ 092364 ("How ClinicaLogic Operates As ClinicaLogic detects inconsistencies and billing problems on-line, clear instructions will display on the claims processing screen, enabling the examiner to make the appropriate decisions. Claim examiners will have the capability to accept the claim for payment, override edits on any or all of the line items or pend the claim for review.") 30(b)(6) deposition ofKarenLampe Deposition of Harrington Benefits

30(b)(6) deposition ofJohn Danza

rejecting medical service codes

which are mutuallyexclusive

Erisco Facets Overview at MCK 002308 ("ClinicalClaims Audit Facets automatically edits every claim that you process with Erisco's proprietary clinical editing software, with tens of thousands of clinical rules and recommendations. This allows you

Erisco ClinicaLogic Marketing Brochure (targeted at ClaimFacts customers) at MCK 034224 ("How ClinicaLogic Works. . . As ClinicaLogicdetects inconsistencies online, it displays clear instructions on the

TriZetto ProductAnnouncement:Introductionof ClinicaLogic Module in OicLink (March 2002) at TRZ 277700 ("Some edits detect and, in certain situations, automatically correct commonly encountered coding errors.

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due to nonmedical criteria with any other medical service codes contained in the at least one claim in response to the determining step. Deposition of Providence Health Plan

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to identzfybilling problemsand eliminatesignificant overpayment ofclaims, and to consistently catch fraudulent, erroneous or inconsistent billing practices, a significant factor in cost containment.")

Claims Processing Screen, enablingthe examiner to make appropriatedecisions. An edit maybe accepted or overridden, or the original claim maybe pended for review.")

Other edits identify potential improprieties regarding claim procedures and diagnoses. ClinicaLogic's flexibility allows

the user to utilize any or all ofthe edits. . . ")

30(b)(6)depositionof JohnDanza

ClaimFacts ClimcaLogic System Overview (January2004) at TRZ092364 ("How ClinicaLogicOperates As ClinicaLogic detects inconsistencies and billing problems on-line, clear instructions will display on the claims processing screen, enabling the examiner to make the appropriate decisions. Claim examiners will have the capability to accept the claim for payment, override edits on any or all of the line items or pend the claim for review.") 30(b)(6) deposition of Karen Lampe Deposition of Harrington Benefits

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3. A computer systemincluding a central processing unit and associated memory for processing input claims containing at least one medical service code, comprising:

Facets Product Overview (Spr 1996) at MCK 002312 ("Facets uses ... the client/server platform, which links individual personal computers to high performance relational database servers Deposition of Providence Health Plan Deposition of Craig Luftig

Erisco ClaimFacts Marketing Brochure at TRZ 032141 ("You can implement ClaimFacts in one oftwo ways,... You can either implement the software at your site, or subscribe to remote service. . . . you choose to license ClaimFacts, our professional support staff will work with you to implement the system on your IBM or equivalent hardware.")

If

TriZetto Product Announcement: Introduction of ClinicaLogic Module in OicLink (March 2002) at TRZ 277700-01 ("Since the claim editing logic is embedded within the [QicLirik] Claims Adjudication program. .

30(b)(6) deposition ofJohnDanza

30(b)(6) deposition ofKaren Lampe Deposition of Harrington Benefits Erisco's Facets and Healthweb at MCK 002352 (figure with "Facets Client" connected to "DBMS") Facets Product Overview (Spr 1996) at MCK002312 ("Facets uses ... the client/server platform, which links individual personal to computers high performance relational database servers ...."). Facets Product Overview (Spr 1996) at 002319 ("ClinicalEdits

a predetermined database stored in the associated memory, the database containingmedical service codes and a set of

Erisco ClaimFacts Marketing Brochure at TRZ 032143 ("IntelligentProcessing.. . ClimcaLogicis backed by an expert staff ofboard-certified physicians. Their combined clinical experience forms an expert-knowledge database, updatedregularly as medicalcriteria change.")

Erisco ClinicaLogic Marketing Brochure (targeted at ClaimFacts customers) at MCK 034224 ("An Expert

TriZetto Product Announcement: Introduction of ClinicaLogic Module in OicLink (March 2002) at TRZ 277700 ("the medicaldatabasethat forms the core of ClinicaLogic... [biased on [] collectivemedical claim checkingexperience knowledgeand extensive [contains] over 90,000 clinical rules for claim checking. These rules apply to surgical, laboratory, radiological, anesthesia and other medical procedures as well as to

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relationships among the medical service codes defming whether selected ones of the medical service codes are valid when received with other selected ones of the medical service codes;

Every claim you process is automatically edited by Erisco's proprietary clinical editing software, with tens of thousands of clinical rules and recommendations. ... Facets clinical editing clearly identifies potential problems, such as unbundledsurgical procedures, claims billed incorrectly due to coding errors, unacceptable procedures and potentially fraudulent information. It also checks for invalid data relationships (like an inconsistency between diagnosis and procedure codes) and patternsof outpatient and inpatient utilization that deviate from the accepted standards

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Knowledge-based System... ClinicaLogic is backed by a staff of board-certified physicians [whose] expertise forms the medical logicand review criteria database, the core of ClinicaLogic. This expertknowledge database is updated regularly as medical criteria change, making ClinicaLogic the most comprehensive claims editor available today.")

diagnoses.")

30(b)(6) deposition of JohnDanza

of clinical practice.")

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Erisco Facets Overview (webpage) at MCK002308 ("Clinical Claims Audit Facets automatically edits every claim that you process with Erisco 's proprietary clinical editing software, with tens ofthousands ofclinical rules and recommendations.This allows you to identify billing problems and eliminate significant overpayment of claims, and to consistently catch fraudulent, erroneous or inconsistent billing practices, a significant factor in cost containment.") Facets Product Overview (Spr 1996) at MCK 002316 ("Claims Processing ... Claims processing utilizes diagnosis codes and procedure codes to read service based rules ....") M*Plan ProviderPerspective (Spr 2004) at MCK 002355 ("the PACE clinical editing system ... will encompass a comprehensive set of clinical claims editing criteria that will allow for the evaluation of medicalbilling information and CPT coding accuracy.") Deposition of Providence HealthPlan

ClaimFacts ClinicaLogic System Overview (January 2004) at TRZ 092356 ("Team of Specialists the medicaldatabase that forms the core of ClinicaLogic [has] over 90,000 clinical rules for claim checking. Theserules apply to surgical, laboratory, radiological, anesthesia and other medical procedures as well as to diagnoses. Eachrule for a procedure includes medical data that indicate either an appropriate way to adjudicate the procedure or a proper relationship between the procedure and information such as the patient's age and sex.") 30(b)(6) deposition of Karen Lampe Deposition of Harrington Benefits

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means for receiving at least one claim;

Erisco Facets Overview (webpage) at MCK002308 ("Clinical Claims Audit Facets automatically edits every claim that you process with Erisco's proprietary clinical editing software ....") Facets Product Overview (Spr 1996) at MCK 002316 ("Claims Entry Claims can be entered online or electronically via proprietary format or the industry standard ...").

Erisco ClaimFacts Marketing Brochure at TRZ 032143 ("IntelligentProcessing. . . Clinical Logic is ClaimFacts' integrated medical claim editor. It automatically examines each claim instantly on-line, as it is processed.")

TriZetto Product Announcement: Introduction of

Id. ("Duplicate work is eliminated because you only have to enterdate once. ClaimFacts automatically captures and stores original and medical edit information as it is entered

ClinicaLogic Module in OicLink (March 2002) at TRZ 277699 ("ClinicaLogic is a comprehensive, knowledgebasedmodule designed to automatically check medical claims beforepayment.... ClincaLogic. . . checks claims as theyare entered manually on-line or in batch mode. .

ClinicaLogic User Guide (2004) at TRZ 154738

8

Page 14 of 130

M*PlanProvider Perspective (Spr 2004) at MCK002355 ("the PACE clinical editing system ... willbe implemented on claims with dates of service beginning May 1, 2004")
on-line.") Deposition of Providence Health Plan

Erisco ClinicaLogic Marketing Brochure (targeted at ClaimFacts customers) at MCK 034224 ("A Flexible, Integrated Solution. . . With ClinicaLogic you can screen existing claims data instantly as they are entered online or Works Whena batch-processed. . . . How ClinicaLogic claim is entered, ClinicaLogic compares. .

("ClinicaLogic runs seanilessly with QicLink claim processing by verifying claim data as it is entered.")

30(b)(6) deposition ofJohnDanza

Filed 07/07/2006

ClaimFacts ClinicaLogic System Overview (January 2004) at TRZ 092364 ("How ClinicaLogicOperates Claims entered to ClaimFacts are first examined. .

30(b)(6) depositionof Karen Lampe Deposition of Harrington Benefits means for ascertaining whether the at least one claim contains a plurality of medical service codes; DepositionofProvidence Health Plan means for determining whether one of the medical service codes in the plurality of medicalservice codes is valid or invalid by interacting with Facets Product Overview (Spr 1996) at MCK002319 ("Clinical Edits Every claim you process is automatically edited by Erisco's proprietary clinical editing software, with tens ofthousands of clinical rules and recommendations. ... Facets clinical editing clearly identifies potential problems, such as unbundled surgical procedures, claims billedincorrectly due to coding errors, unacceptable procedures and potentially fraudulent information. It also checks for invaliddata relationships (like an inconsistency between diagnosis and procedure codes) and patterns of outpatient and inpatient utilization that deviate from the accepted standards M*Plan Provider Perspective (Spr 2004) at MCK 002355 ("The PACE clinical editing system is designed to detect ... several CPT codes ....") Unbundling/Rebundling -- Billing under
Facets Product Overview (Spr 1996) at MCK002319 ("Clinical Edits Facets clinical editing clearly identifies potential problems, such as unbundled surgical procedures ....")

Document 457-4

Erisco ClinicaLogic Marketing Brochure (targeted at ClaimFacts customers) at MCK 004812 ("When a claim is entered, ClinicaLogic compares procedure codes from multiple services, flagging potential problems.") 30(b)(6) deposition ofKaren Lampe Deposition

ofHarrington Benefits

TriZetto Product Announcement: Introduction of ClimcaLogic Module in QicLink (March 2002) at TRZ 277699 ("ClinicaLogic. . . checks claims as they are entered manually on-line or in batchmode. . . to identify: "unbundled"procedures coveredby one (i.e., procedures comprehensive CPT/HCPCS procedure code that are itemized on the provider's bill, possibly resulting in an overstatement of charges).")

30(b)(6) deposition of JohnDanza

Case 1:04-cv-01258-SLR

Erisco ClaimFacts Marketing Brochure at TRZ 032143 ("IntelligentProcessing... ClinicaLogic warns you of questionable provider fees before disbursement. And it corrects "unbundling," unacceptable procedures, coding errors and more. It even checks for inadvertent or potentially fraudulent deviations from accepted clinical standards.") 30(b)(6) deposition ofKaren Lampe

TriZetto Product Announcement: Introduction of ClinicaLogic Module in QicLink (March 2002) at TRZ 277699 ("ClinicaLogic is a comprehensive, knowledgebased module designed to automatically check medical claims before payment. . .. ClincaLogic.. . checks claims as they are entered manually on-line or in batch mode. .

30(b)(6) deposition ofJohnDanza

the database and the set of

of clinical practice.")

Deposition

ofHaningtonBenefits

9

Filed 07/07/2006

Page 15 of 130

relationships contained in the database;

M*Plan ProviderPerspective (Spr 2004) at MCK 002355 ("the PACE clinical editing system ... will allow for the evaluation of medicalbilling information and CPT coding accuracy. ... The PACEclinical editing system is designed to detect irregularities in medical billings, such as: Incidental Procedures -- Procedures which are carried out at the same time as a primary procedure, require little additional physician resources, are clinically integral to the performance of the primaryprocedure; and therefore, should not be reimbursed separately. Mutually Exclusive/Redundant Procedures -- Defined as the billing oftwo or more procedures that, by medical practice standards, would not be billed on the same date of service. Unbundling/Rebundling-- Billing under several CPT codes that should be combined undera single charge.") Deposition of Providence HealthPlan

Document 457-4

means for authorizing medical service codes which are valid in response to the means for determining; and Deposition of Providence Health Plan

Erisco Facets Overview at MCK 002308 ("Clinical Claims Audit Facets automatically edits every claim that you process with Erisco's proprietary clinical editing software, with tens of thousands of clinical rules and recommendations. This allows you to identzfy billing problemsandeliminatesignificant overpayment ofclaims, and to consistently catch fraudulent, erroneous or inconsistent billing practices, a significant factor in cost containment.")

Erisco ClmmcaLogic Marketing Brochure (targeted at ClaimFacts customers) at MCK 034224 ("How ClinicaLogic Works.. . As ClinicaLogicdetects inconsistencies online,it displays clear instructions on the Claims Processing Screen, enablingthe examiner to make appropriatedecisions. An edit may be acceptedor overridden, or the original claim maybe pended for review.")

TriZetto Product Announcement: Introduction of ClinicaLogic Module in OicLink (March 2002) at TRZ 277700 ("Some edits detect and, in certain situations, automatically correct commonly encountered coding errors. Other edits identify potential improprieties regarding claim procedures and diagnoses. ClinicaLogic's flexibility allows

the user to utilize any or all of the edits. . .

30(b)(6) depositionof John Danza

Case 1:04-cv-01258-SLR

ClaimFacts ClinicaLogic System Overview (January 2004) at TRZ 092364 ("How ClinicaLogic Operates As ClinicaLogic detects inconsistencies and billing problems on-line, clear instructions will display on the claims processing screen, enabling the examiner to make the appropriate decisions. Claim examiners will have the capability to acceptthe claim for payment, override edits on any or all of the line items or pend the claim for review.") 30(b)(6) deposition ofKaren Lampe Deposition of Harnngton Benefits

means for

Erisco Facets Overview at MCK 002308 ("ClinicalClaims Audit

Erisco ClinicaLogic Marketing Brochure (targetedat

TriZetto Product Announcement: Introduction of

10

Page 16 of 130

rejecting medical service codes which are invalid in response to the means for determining.

Facets automaticallyeditsevery claim that you process with Erisco's proprietary clinical editing software, with tens of thousands ofclinical rules and recommendations. This allows you to identify billing problemsand eliminatesignificant overpayment ofclaims, and to consistently catch fraudulent, erroneous or inconsistent billing practices, a significant factor in cost containment.") Deposition

ClaimFacts customers) at MCK 034224 ('How ClinicaLogic Works. . . As ClinicaLogicdetects inconsistencies online,it displays clear instructions on the Claims Processing Screen, enablingthe examinerto make appropriatedecisions. An edit maybe accepted or overridden, or the original claim maybe pended for review.")

ClinicaLogic Module in QicLink (March2002) at TRZ 277700 ("Some edits detect and, in certain situations, automatically correct commonly encountered coding errors. Other edits identify potential improprieties regarding claim procedures and diagnoses. ClinicaLogic's flexibility allows the user to utilize any or all of the edits. .

Filed 07/07/2006

ofProvidence Health Plan

ClaimFacts ClinicaLogic System Overview (January 2004) at TRZ 092364 ("How ClinicaLogic Operates As ClinicaLogic detects inconsistencies and billing problems on-line, clear instructions will display on the claims processing screen, enabling the examiner to make the appropriate decisions. Claim examiners will have the capability to accept the claim for payment, override edits on any or all of the line items or pend the claim for review.") 30(b)(6) deposition ofKaren Lampe

30(b)(6) deposition ofJolm Danza

Document 457-4

Deposition of HaningtonBenefits

Case 1:04-cv-01258-SLR

11

Page 17 of 130

4. The apparatus of claim 3, further comprising means for revising the at least one claim to
Deposition ofProvidence HealthPlan

Facets Product Overview (Spr 1996) at MCK 002319 ("Clinical Edits Every claim you process is automatically edited by Erisco's proprietary clinical editing software ....")

Filed 07/07/2006

delete invalid medicalservice
codes.

Erisco ClinicaLogic Marketing Brochure (targeted at ClaimFacts customers) at MCK 034224 ("How ClinicaLogic Works . . . As ClinicaLogic detects inconsistencies online,it displays clear instructions on the Claims Processing Screen, enabling the examiner to make appropriatedecisions. An edit may be accepted or overridden, or the original claim maybe pended for review.")

TriZetto Product Announcement: Introduction of ClinicaLogic Module in OicLink (March 2002) at TRZ 277700 ("Some edits detect and, in certain situations, automatically correct commonly encountered coding errors. Other edits identify potential improprieties regarding claim procedures and diagnoses. ClinicaLogic's flexibility allows the user to utilize any or all of the edits. . . ")

30(b)(6) depositionof JohnDanza

Document 457-4

ClaimFacts ClinicaLogic System Overview (January 2004) at TRZ 092364 ("HowClinicaLogic Operates As ClinicaLogic detects inconsistencies and billing problems on-line, clear instructions will display on the claims processing screen, enabling the examiner to make the appropriate decisions. Claim examiners will have the capability to acceptthe claim for payment, override edits on any or all ofthe line items or pend the claim for review.") 30(b)(6) deposition ofKarenLampe Deposition

ofHarrington Benefits

Case 1:04-cv-01258-SLR

5. The apparatus of claim 4, further comprising means for informing a user why the at least one claim was revised.

Facets Product Overview (Spr 1996) at MCK 002319 ("Clinical Edits Every claim you process is automatically edited by Erisco's proprietary clinical editing software ....") Deposition of Providence Health Plan

Erisco ClinicaLogic Marketing Brochure (targeted at ClaimFacts customers) at MCK 034224 ("How ClinicaLogic Works. . . As ClinicaLogicdetects inconsistencies online,it displays clear instructions on the Claims Processing Screen, enablingthe examinerto make appropriatedecisions. An edit may be accepted or overridden, or the original claim maybe pended for review.")

TriZetto Product Announcement: Introduction of ClinicaLogic Module in OicLink (March 2002) at TRZ 277700 ("Some edits detect and, in certain situations, automatically correct commonly encountered coding errors. Other edits identify potential improprieties regarding claim procedures and diagnoses. ClinicaLogic's flexibility allows the user to utilize any or all of the edits. . . ")

ClaimFacts ClinicaLogic System Overview (January 2004) at TRZ092364 ("How ClinicaLogicOperates As ClinicaLogic detects inconsistencies and billing problems on-line, clear instructions will display on the claims 12

30(b)(6) deposition of John Danza

Page 18 of 130

processing screen, enablingthe examiner to make the appropriate decisions. Claim examiners will have the capability to acceptthe claim for payment, override edits on any or all of the line items or pend the claim for review.") 30(b)(6) deposition ofKaren Lampe Deposition ofHarrington Benefits

Filed 07/07/2006

6. The apparatus

ofclaim 3,
wherein the database containing medical service codes includes medicalservice codes described Deposition of Providence HealthPlan

M*Plan Provider Perspective (Spr 2004) at MCK 002355 ("the PACE clinical editing system ... willencompass a comprehensive set of clinical claims editing criteria that will allow for the evaluation

of medical billing information and CPT coding accuracy.")

Erisco ClinicaLogic Marketing Brochure (targeted at ClaimFacts customers) at MCK 004813 ("The ClinicaLogic medical editor screens claims for surgical, laboratory, radiological, and other medical procedures based on CPT-4 codes.")

Document 457-4

by CPT codes.

ClaimFacts ClinicaLogic System Overview (January 2004) at TRZ092356 ("Deloitte & Touche assigned clinical rules to over 8,900 CPT/HCPCSprocedure codes.") 30(b)(6) deposition ofKaren Lampe Deposition of Harrington Benefits

TriZetto Product Announcement: Introduction of ClinicaLogic Module in QicLink (March2002) at TRZ 277699 ("The ability of ClinicaLogic to detect and correct billing problems makes it a valuable tool to identify routine CPT/HCPCS and ICD-9 coding errors and coding strategies some providers use to circumvent reasonable and customary limits.")

30(b)(6) deposition of John Danza

Case 1:04-cv-01258-SLR

!
8. The apparatus ofclaim 3, further comprising means for requesting further information from a user regarding the at least one claim.

Facets Product Overview (Spr 1996) at MCK 002319 ("Clinical Edits Every claim you process is automatically edited by Erisco's proprietary clinical editing software .. ..")

Erisco ClinicaLogic Marketing Brochure (targeted at ClaimFacts customers) at MCK 034224 ("How ClinicaLogicWorks. . . As ClinicaLogic detects inconsistencies online, it displays clear instructions on the ClaimsProcessing Screen, enabling the examinerto make appropriate decisions. An edit may be accepted or overridden,or the original claim maybe pended for
review.")

TriZetto ProductAnnouncement:Introductionof ClinicaLogic Module in QicLink (March 2002) at TRZ 277700 ("Some edits detect and, in certain situations, automatically correctcommonly encountered coding errors. Other edits identify potential improprieties regarding claim procedures and diagnoses. ClinicaLogic's flexibility allows

the user to utilize any or all of the edits. . . ")

ClaimFacts ClinicaLogic System Overview (January 2004)

30(b)(6) deposition of JohnDanza

at TRZ 092364 ("How ClinicaLogic Operates As

13

Page 19 of 130

ClinicaLogic detects inconsistencies and billing problems on-line, clear instructions will display on the claims processing screen, enabling the examiner to make the appropriate decisions. Claim examiners will have the capability to accept the claim for payment, override edits on any or all of the line items or pend the claim for review.") 30(b)(6) deposition of Karen Lampe Deposition of Harrington Benefits

Filed 07/07/2006

Document 457-4

9. The apparatus of claim 3, wherein the relationships among the medical service codes include medically determined relationships.

Erisco Facets Overview (webpage) at MCK 002308 ("Clinical Claims Audit Facets automatically edits every claim that you process with Erisco's proprietary clinical editing software, with tens

of thousands of clinical rules and recoimnendations.")

Facets Product Overview (Spr 1996) at MCK 002319 ("Clinical Edits Every claim you process is automatically edited by Erisco's proprietary clinical editing software, with tens ofthousands of clinical rules and recommendations.")

Erisco ClinicaLogic Marketing Brochure (targeted at ClaimFacts customers) at MCK 034224 ("An Expert Knowledge-basedSystem... ClinicaLogic is backed by a staff of board-certified physicians [whose] expertise forms the medical logic and review criteria database, the core ofClinicaLogic. This expert knowledge database is updatedregularly as medical criteria change, making ClinicaLogic the most comprehensive claims editor available today.")

TriZetto Product Announcement: Introduction of ClinicaLogic Module in QicLink (March2002) at TRZ 277700 ("the medicaldatabasethat forms the core of ClinicaLogic.. . [b]ased on [] collectivemedicalknowledge and extensive claim checkingexperience [contains]over 90,000 clinical rules for claim checking. These rules apply to surgical, laboratory, radiological, anesthesia and other medical procedures as well as to diagnoses.")

M*PlanProvider Perspective (Spr 2004) at MCK 002355 ("the

PACE clinical editing system ... willencompass a comprehensive set of clinical claims editing criteria that will allow for the evaluation ofmedical billing information and CPT coding accuracy.") Deposition of Providence HealthPlan

Case 1:04-cv-01258-SLR

ClaimFacts ClinicaLogic System Overview (January 2004) at TRZ092356 ("Team of Specialists the medical database that forms the core of ClinicaLogic [has] over 90,000 clinical rules for claim checking. Theserules apply to surgical, laboratory, radiological, anesthesia and other medical procedures as well as to diagnoses. Eachrule for a procedure includes medical data that indicate either an appropriate way to adjudicate the procedure or a proper relationship between the procedure and information such as the patient's age and sex.") 30(b)(6) deposition of Karen Lampe Deposition of Harrington Benefits

30(b)(6) deposition of John Danza

14

Page 20 of 130

Filed 07/07/2006

10. A computer system including a central processing unit and associated memory for processing input claims containing at least one medical service claim, comprising:
Deposition

Facets Product Overview (Spr 1996) at MCK 002312 ("Facets uses ... the client/server platform, which links individual personal computers to high performance relational database servers ....").

CJIS

QICU

of Providence HealthPlan

Erisco ClaimFacts Marketing Brochure at TRZ 032141 ("You can implement ClaimFacts in one of two ways, . - You caneitherimplementthe softwareat your site, or subscribe to remote service.... If you choose to license ClaimFacts, our professional support staff will work with you to implement the system on your IBMor equivalent hardware.") 30(b)(6) deposition of Karen Lampe Deposition of Harrington Benefits

TriZetto Product Announcement: Introduction of

ClinicaLogic Module in QicLink (March 2002) at TRZ 277700-01 ("Since the claim editing logic is embedded withinthe [QicLink] Claims Adjudication program. .

30(b)(6) deposition ofJohnDanza

Case 1:04-cv-01258-SLR

a predetermined database stored in the associated memory, the database containing medical service codes and a set of relationships among the medical service codes defining whether selected ones of the medical service codes are valid when received with other selected ones of the medical service codes;

Erisco's Facets and Healthweb at MCK 002352 (figure with "Facets Client" connected to "DBMS") Facets Product Overview (Spr 1996) at MCK 002312 ("Facets uses ... the client/server platform, whichlinks individual personal computers to high performance relational database servers ....").
Facets Product Overview (Spr 1996) at MCK002319 ("Clinical Edits Every claim you process is automatically edited by Erisco's proprietary clinical editing software, with tens of thousands of clinical rules and recommendations. ... Facets clinical editing clearly identifies potential problems, such as unbundled surgical procedures, claims billed incorrectly due to coding errors, unacceptable procedures and potentially fraudulent information. It also checks for invalid data relationships (like an inconsistency between diagnosis and procedure codes) and patterns of outpatient and inpatient utilization that deviate from the accepted standards of clinical practice.")

Document 457-4

Erisco ClaimFacts Marketing Brochure at TRZ 032143 ("Intelligent Processing.. . CliicaLogic is backed by an expert staff ofboard-certified physicians. Their combined clinical experience forms an expert-knowledge database, updated regularly as medicalcriteria change.")

Erisco ClinicaLogic Marketing Brochure (targeted at ClaimFacts customers) at MCK 034224 ("An Expert Knowledge-based System.. . ClinicaLogicis backed by a staff ofboard-certified physicians [whose] expertise forms the medical logic and review criteria database, the core of ClinicaLogic. This expert knowledge database is updated regularly as medical criteria change, making ClinicaLogic the most comprehensive claims editor available today.")

TriZetto Product Announcement: Introduction of ClinicaLogic Module in QicLink (March 2002) at TRZ 277700 ("the medicaldatabasethat forms the core of ClinicaLogic. .. [biased on [] collectivemedical claim checkingexperience knowledgeand extensive [contains]over 90,000clinical rules for claim checking. Theserules applyto surgical, laboratory, radiological, anesthesia and other medical procedures as well as to diagnoses.")

30(b)(6) deposition of John Danza

Erisco Facets Overview (webpage)at MCK 002308 ("Clinical Claims Audit Facets automatically edits every claim that you process with Erisco's proprietary clinical editing software, with tens ofthousandsofclinical rules and recommendations. This allows you to identify billing problems and eliminate significant overpayment ofclaims, and to consistently catch fraudulent, erroneous or inconsistent billingpractices, a significant factor in

ClaimFacts ClinicaLogic System Overview (January 2004) at TRZ 092356 ("Team of Specialists the medical database that forms the core of CliicaLogic [has] over 90,000 clinical rules for claim checking. These rules apply to surgical, laboratory, radiological, anesthesia and other medical procedures as well as to diagnoses. Eachrule for a procedure includes medical data that indicate either an appropriate way to adjudicate the procedure or a proper relationship between the procedure and information such as the patient's age and sex.")

15

Page 21 of 130

cost containment.") Facets Product Overview (Spr 1996) at MCK 002316 ("Claims utilizes diagnosis codesand Processing ... Claims processing codesto read service based rules . . .1?) procedure
.

30(b)(6) deposition of Karen Lampe Deposition of Harrington Benefits

Filed 07/07/2006

M*Plan ProviderPerspective (Spr 2004) at MCK002355 ("the PACE clinical editing system ... will encompass a comprehensive set ofclinical claims editing criteria that will allow for the evaluation of medical billing information and CPT coding accuracy.") Deposition of Providence Health Plan means for receiving at least one claim; Erisco Facets Overview (webpage) at MCK 002308 ("Clinical Claims Audit Facets automatically edits every claim that you process with Erisco's proprietary clinical editing software ....")
Facets Product Overview (Spr 1996) at MCK 002316 ("Claims

Erisco ClaimFacts Marketing Brochure at TRZ 032143 ("Intelligent Processing... Clinical Logic is ClaimFacts' integrated medical claim editor. It automatically examines each claim instantly on-line, as it is processed.")

TriZetto Product Announcement: Introduction of

Document 457-4

Entry Claims can be entered online or electronically via proprietary
format or the industry standard ..."). M*Plan ProviderPerspective (Spr2004) at MCK 002355 ("the PACE clinical editing system ... willbe implemented on claims with dates of service beginning May 1, 2004") Deposition ofProvidence HealthPlan

Id. ("Duplicate work is eliminated because you only have to enter date once. ClaimFacts automatically captures and stores original and medical edit information as it is entered on-line.")

ClinicaLogic Module in OicLink (March 2002) at TRZ 277699 ("ClinicaLogic is a comprehensive, knowledgebasedmodule designed to automatically check medical claims before payment.. .. ClincaLogic.. . checks claims as they are entered manually on-line or in batch mode. .

Case 1:04-cv-01258-SLR

Erisco ClinicaLogic Marketing Brochure (targeted at ClaimFacts customers) at MCK 034224 ("A Flexible, Integrated Solution. . . With ClinicaLogic you can screen existing claims data instantly as they are entered online or batch-processed. . . . How ClinicaLogic Works When a claim is entered, ClimcaLogic compares. .

ClinicaLogicUser Guide (2004) at TRZ 154738 ("ClinicaLogic runs seamlessly with QicLink claim processing by verifying claim data as it is entered.")

30(b)(6) deposition of JohnDanza

ClaimFacts ClinicaLogic System Overview (January 2004) at TRZ 092364 ("How ClinicaLogic Operates Claims entered to ClaimFacts are first examined. .

30(b)(6) deposition of Karen Lampe Deposition ofHarnngtonBenefits means for

M*PlanProvider Perspective (Spr 2004) at MCK 002355 ("The

Erisco ClinicaLogic Marketing Brochure (targeted at 16

TriZetto Product Announcement: Introduction of

Page 22 of 130

ascertaining whether the at least one claim contains a plurality of medical service codes;
Facets Product Overview (Spr 1996) at MCK 002319 ("Clinical Edits Facets clinical editing clearlyidentifies potential problems, such as unbundled surgical procedures ....") Deposition

PACE clinical editing systemis designed to detect ... Unbundling/Rebundling -- Billing under several CPT codes ....")

ClaimFacts customers) at MCK004812 ("When a claim is entered, ClinicaLogic compares procedure codes from multiple services, flagging potential problems.") 30(b)(6) deposition of Karen Lampe Deposition ofHarrington Benefits

of Providence Health Plan

ClinicaLogic Module in QicLink (March 2002) at TRZ 277699 ("ClinicaLogic.. . checks claims as they are entered manually on-line or in batchmode. . . to identify: "unbundled"procedures coveredby one (i.e., procedures comprehensive CPT/HCPCS procedure code that are itemized on the provider's bill, possiblyresulting in an overstatement of charges).")

Filed 07/07/2006

means for determining whether one ofthe medical service codes in the at least one claim is included in any other medical M*Plan Provider Perspective (Spr 2004) at MCK 002355 ("The PACE clinical editing system is designed to detect irregularities in medical billings, such as: ... Unbundling/Rebundling -- Billing under several CPT codes that should be combined under a single charge.") Facets Product Overview (Spr 1996) at MCK002319 ("Clinical Edits Facets clinical editing clearlyidentifies potential problems, such as unbundled surgical procedures ....")
Deposition

Document 457-4

service code in the at least one claim;

Erisco ClinicaLogic Marketing Brochure (targeted at ClaimFacts customers) at MCK 004812 ("ClinicaLogic corrects unbundling.. . For example, obstetrician may an bill separately for prenatal care and delivery and postpartum care. ClinicaLogic detects and properly combines these codes as one, less costly, comprehensive procedure for complete obstetrical care. This leads to substantial savings.")

TriZetto Product Announcement: Introduction of ClinicaLogic Module in QicLink (March2002) at TRZ 277699 ("ClinicaLogic.. . checks claims as theyare entered manually on-line or in batch mode. . . to identify: "unbundled" coveredby one procedures (i.e., procedures comprehensive CPT/HCPCS procedure code that are itemized on the provider's bill, possiblyresulting in an overstatement of charges).")

of Providence Health Plan

ClaimFacts ClinicaLogic System Overview (January2004) at TRZ 092354-55 ("ClaimFactsClinicaLogic Subsystem [ClinicaLogic] checks claims as they are entered on-line or in batch mode to identify: .. . "unbundled" procedures (i.e., procedures covered by one comprehensive CPT/HCPCS procedure code that are itemized on the provider's bill, possibly resulting in an overstatement of charges.") 30(b)(6) deposition ofKaren Lampe Deposition ofHarrington Benefits

30(b)(6) deposition of JoIm Danza

Case 1:04-cv-01258-SLR

means for authorizing medicalservice codes which are not contained in any other medical service code; and

Erisco Facets Overview at MCK 002308 ("ClinicalClaims Audit Facets automatically editsevery claim that you process with Erisco's proprietary clinical editing software, with tens of thousands of clinical rules and recommendations. This allows you to identify billing problems and eliminatesignficant overpayment ofclaims, and to consistently catchfraudulent, erroneous or inconsistent billing practices, a significant factor in costcontainment.") Deposition of Providence HealthPlan

Erisco ClinicaLogic Marketing Brochure (targeted at ClaimFacts customers) at MCK 034224 ("How ClinicaLogicWorks.. . As CliicaLogic detects inconsistencies online, it displays clear instructions on the Claims Processing Screen, enablingthe examinerto make appropriatedecisions. An edit maybe acceptedor overridden, or the original claim maybe pended for review.")

TriZetto Product Announcement: Introduction of ClimcaLogic Module in OicLink (March 2002) at TRZ 277700 ("Some edits detect and, in certain situations, automatically correct commonly encountered coding errors. Other edits identify potential improprieties regarding claim procedures and diagnoses. CliicaLogic's flexibility allows the user to utilize any or all of the edits. . .

ClaimFacts ClinicaLogic System Overview (January 2004) 17

30(b)(6) deposition of John Danza

Page 23 of 130

at TRZ 092364 ("How ClinicaLogic Operates As ClinicaLogic detects inconsistencies and billing problems on-line, clear instructions will display on the claims processing screen, enabling the examiner to make the appropriate decisions. Claim examiners will have the capability to acceptthe claim for payment, override edits on any or all ofthe line items or pend the claim for review.")
30(b)(6) deposition of Karen Lampe Deposition of Harrington Benefits means for rejecting medical service codes Erisco Facets Overview at MCK 002308 ("Clinical Claims Audit Facets automaticallyeditsevery claim that you process with Erisco's proprietary clinical editing software, with tens of thousands of clinical rules and recommendations. This allows you to identify billing problemsand eliminatesignificantoverpayment ofclaims, and to consistently catch fraudulent, erroneous or inconsistent billing practices, a significant factor in cost containment.") Deposition ofProvidence Health Plan

Filed 07/07/2006

whichare
contained in any other medical service code.

Document 457-4

Erisco ClinicaLogic Marketing Brochure (targeted at ClaimFacts customers) at MCK034224 ("How ClinicaLogic Works.. . As ClinicaLogicdetects inconsistencies online, it displays clear instructions on the Claims Processing Screen, enablingthe examiner to make appropriatedecisions. An edit may be accepted or overridden, or the original claim maybe pended for review.")

TriZetto Product Announcement: Introduction of ClinicaLogic Module in Q