In Ruiz v. Podolsky (2010) 50 Cal.4th 838, the Supreme Court carved out an exception to this rule. There, a patient had entered into an arbitration agreement with a doctor. (Id. at p. 841.) The agreement provided that it was binding on "' . . . all parties whose claims may arise out of or relate to treatment or service provided by the physician including any spouse or heirs of the patient . . . ." (Id. at pp. 841-842.) It also specifically provided for arbitration of wrongful death claims. (Id. at p. 842.) The agreement was in conformity with Code of Civil Procedure section 1295 (Ruiz v. Podolsky, supra, 50 Cal.4th at p. 841), which prescribes certain wording and formatting requirements for any agreement to arbitrate a dispute as to the "professional negligence" of a "health care provider." (See id. at p. 843.) The court noted that "section 1295, subdivision (a) contemplates arbitration 'of any dispute as to professional negligence of a health care provider.' '"Professional negligence"' is defined in section 1295, subdivision (g)(2) as 'a negligent act or omission to act by a health care provider in the rendering of professional services, which act or omission is the proximate cause of a personal injury or wrongful death.' " (Ruiz v. Podolsky, supra, 50 Cal.4th at p. 849.) The court then held that "section 1295, construed in light of its purpose, is designed to permit patients who sign arbitration agreements to bind their heirs in wrongful death actions." (Ruiz v. Podolsky, supra, 50 Cal.4th at p. 849.) It concluded that "all wrongful death claimants are bound by arbitration agreements entered into pursuant to section 1295, at least when, as here, the language of the agreement manifests an intent to bind these claimants." (Id. at p. 841.)