The corporate health care industry typically presents a united front in defense of for-profit medicine — but in a new letter to regulators, the hospital industry has detailed some of the most abusive techniques being used by insurers to fleece Americans.

The insidious details were spelled out by the Federation of American Hospitals (FAH) in a letter responding to a federal rule aiming to limit surprise billing. Though FAH’s comments defend the group’s own for-profit interests, the filing from FAH president and CEO Chip Kahn — himself a former insurance lobbyist — offers a detailed look at the ways insurance companies mistreat patients to boost their own bottom line.

Health insurance companies, noted Kahn, “have deployed a range of unfair payment practices and abuses to inappropriately deny coverage of emergency services,” and employ “many other unfair and abusive plan practices that result in surprise bills for patients and/or burden providers and facilities with underpayments and disputes.”