Arizona AG and SimonMed Settle Over Upfront Billing and Delayed Refunds

Arizona Attorney General Kris Mayes announced on January 20, 2026 that her office entered into a consent judgment with SimonMed Imaging MSO, LLC (SimonMed), resolving an investigation into the company’s billing and refund practices related to up-front patient payments and insurance adjudication. The settlement requires SimonMed to reform those practices and pay civil penalties, restitution and fees.

How the State Sees It

• The State alleges SimonMed routinely required patients to make up front payments based on good faith estimates from a third-party tool of what insurance might ultimately cover, and then failed to issue refunds for overpayments within a reasonable time (with some refunds delayed more than a year). 
• The complaint also alleges that although SimonMed offered a “tokenization” option (to charge a patient’s card only after insurance adjudication), front-line staff often did not present that option unless the patient complained about the billing process. 
• Under the consent judgment, SimonMed must, among other requirements, issue refunds within an average of 60 days after insurance adjudication, actively offer the tokenization option to all customers, pay $50,000 in civil penalties, $20,000 in restitution, and $20,000 in costs and fees, and implement detailed reporting and consumer notice obligations over the next five years. 

Conclusion

The SimonMed settlement underscores how state AGs are evaluating patient billing through a consumer communication lens, not just an accounting one to determine unfair and deceptive practices. The State’s theory appears to center on whether patients clearly understood their payment options, knew what to expect after insurance adjudication, and received timely follow-ups when things went wrong. From this we can deduce:

• Clear, proactive communication about payment options and refund timing matters as much as the underlying policy.
• Patient complaints, especially about billing confusion or delayed refunds, can trigger enforcement if they are not tracked and resolved efficiently and consistently.
• Refund delays that stretch beyond expectations, even without intent, create risk when they appear systemic.

We help clients pressure-test patient facing communications, complaint escalation paths, and refund workflows to reduce friction points that often draw regulatory scrutiny. Reach out to us by email for more information on how we can help.

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