On July 1, 2017, Blue Cross Blue Shield of Georgia (BCBSGA), an Anthem affiliate, began enforcing an existing policy that the insurer will not reimburse for non-urgent emergency department visits. In late May 2017, BCBSGA sent notices to its members explaining the provisions of the policy, and that it intended to use retrospective claim review to refuse to cover inappropriate emergency department visits. The letter defined inappropriate use as a visit for symptoms for any but those that “a prudent layperson, possessing an average knowledge of medicine and health,” would believe needed immediate treatment. The notice encouraged members with . . .