One cannot patent anything that naturally exists. But one can patent strategies. Business methods, medical, and, until recently, tax strategies can be patented. Tax strategy patents were recently banned in the America Invents Act. There has been legislation to ban medical strategy/method patents, and frankly I'm surprised it hasn't been banned yet legislatively. And the federal courts in the past have limited business strategy patents (Bilski v. Kappos). It seems to me SCOTUS should move to limit medical strategy patents in their decision. But if they don't, this may spur Congress to actually do something.