LOS ANGELES - In reversing a lower court decision, a California appeals panel on Feb. 19 held that emergency room physicians alleged sufficient facts to reflect the existence of a claim for negligent delegation asserted against health maintenance organizations for allegedly knowing that their independent practice associations (IPAs) were unable to pay the physicians for providing statutorily required services (Centinela Freeman Emergency Medical Associates, et al. v. Health Net of California Inc., et al., No. B238867, Calif. App., 2nd. Dist., Div. 3; 2014 Cal. App. LEXIS 158).