UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF FLORIDA 

TALLAHASSEE DIVISION 

AIR METHODS CORPORATION and 

ROCKY MOUNTAIN HOLDINGS, 

 Case No. 4:20-cv-00462-AW-MAF 

Plaintiffs, 

vs. 

DAVID ALTMAIER, in his official 

capacity as Commissioner of the 

Office of Insurance Regulation, 

 

Defendant. 

___________________________________/ 

DECLARATION OF JEFF SEE 

I, Jeff See, being of legal age, declare the following: 

1. I reside in the State of Florida. I am the Senior Vice President for 

Customer Experience for Air Methods Corporation (“Air Methods”) and its 

wholly-owned subsidiary Rocky Mountain Holdings LLC (“Rocky Mountain”) 

(collectively, “Air Methods”). 

2. This Declaration is based upon my personal knowledge, my 

independent investigation, and my review of the records of Air Methods. It is 

submitted in support of Air Methods’ response to Defendant’s motion to dismiss 

the Complaint, which seeks declaratory and injunctive relief to enjoin the 

enforcement of Florida House Bill 747, enacted on September 18, 2020 and 

codified at new Florida Statutes sections 627.42397 and 641.514 (“HB 747”). 

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3. In my capacity as the Senior Vice President of Customer Experience, I 

am familiar with Air Methods’ records, record-keeping procedures, and databases 

relating to, inter alia, their corporate status and operational certificates. I am also 

familiar with Air Methods’ finances and Florida operations. 

4. Air Methods started its operations in Florida in 1980. 

5. Air Methods has 14 different bases located all across Florida: from 

Escambia County in the Panhandle to Jacksonville in Northeast Florida to St. Lucie 

in Southeast Florida to Lee County in Southwest Florida. 

6. Air Methods operates on average one or two emergency air transports 

on a daily basis from each of these 14 locations. For the period from January 1, 

2017 through June 30, 2020, Air Methods annually operated approximately 6,250 

air ambulance transports in the State of Florida. 

7. Air Methods also serves several under-served rural communities, and 

transports patients from these rural communities to higher care facilities located in 

metro areas of Florida. 

8. Air Methods maintains a fleet of air ambulances, fixed-wing aircraft 

and helicopters, that are prepared to respond at a moment’s notice to medical 

emergencies. It provides life-saving emergent air ambulance transportation to 

critically ill or injured patients, while medical professionals provide in-flight care. 

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9. Air Methods is dispatched by first responders at the scene of an 

accident or by a physician or medical facility that determines a patient requires 

emergency transport to a hospital that can offer a higher level of care. 

10. In accordance with federal and state law, Air Methods provides air 

ambulance services regardless of their patients’ insurance status or their ability to 

pay for the services. 

11. Air Methods’ life-saving air ambulance operations are expensive. Air 

Methods’ aircraft are customized to accommodate patient transport and in-flight 

medical care, and each base must be staffed by two pilots per day who work 12-

hour shifts to maintain 24-hour coverage. Air Methods must also employ multiple 

crews of highly trained paramedics and nurses at each base who stand ready to 

provide medical care to patients at the scene of emergencies and during the flights. 

12. Each aircraft must be maintained and fueled so that it can immediately 

respond to any emergency. As a private company (and not a subsidized nonprofit), Air Methods must fund its operations from payments for its services. 

13. The payments Air Methods receives for its services are based largely 

on the patient’s insurance coverage. 

14. Air Methods rarely recovers any payment from patients without 

insurance. For patients covered by Medicaid or Medicare, Air Methods receives 

payments substantially below its costs and billed charges. 

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15. These underpayments contribute to escalating prices for emergency 

air transportation because the cost of undercompensated care is shifted to other 

payors such as commercial insurers or, as a last resort, to patients themselves. 

16. To continue to provide air ambulance service to every patient 

regardless of their ability to pay, Air Methods must receive its billed charges for a 

sufficient proportion of its flights to offset the losses it suffers when it transports 

patients who are uninsured or underinsured. 

17. The enforcement of Florida’s HB 747 law will result in imminent, 

significant economic losses to Air Methods as it precludes Air Methods from 

receiving full payment for its services from insurers. 

18. Under HB 747, health insurers are authorized by the State of Florida 

to provide reimbursement for services in an amount they alone determine is 

“reasonable,” without consideration of Air Methods’ billed charges. 

19. The economic impact will be immediate as Air Methods operates 

daily life-saving flights from each of its 14 bases in Florida. 

 I declare under penalty of perjury that the foregoing is true and correct. 

Executed in the State of Florida on November 13, 2020. 

 

 ________________________ 

 Jeff See 

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