Hospital service plans fulfill a vital social need. In view of the continuing support and apparently expanding activities of the plans, it is well to understand their legal nature. At the present time problems are arising that could not have been foreseen 25 years ago. The favorable treatment which hospital service plans have received under the law should be continued so long as the plans continue realistically to meet these problems as they have in the past.
Leo A. Simpson, Non-Profit Hospital Service Plans, 8 Clev.-Marshall L. Rev. 492 (1959)