Doctor sued Blue Shield in quantum meruit for emergency medical services rendered to two of Blue Shield’s insureds. A quantum meruit claim is governed by a 2-year limitations period under CCP 339. Dr. sued more than two years after Blue Shield sent him Explanation of Benefits forms clearly stating that it refused to pay his claims. The limitations period ran immediately on receipt of the EOB forms denying Dr.’s claims even though Dr. then invoked Blue Shield’s internal appeal process. That process did not toll the running of the limitations period. To the same effect are Singh v. Allstate Ins. Co. (1998) 63 Cal.App.4th 135 and Migliore v. Mid-Century Ins. Co. (2002) 97 Cal.App.4th 592.
The limitations period for a doctor’s claim for payment of services rendered insured patients is not tolled while the doctor invokes the insurer’s internal process for appealing claim denials.