Advance PCS v. Bauer

632 S.E.2d 95, 280 Ga. 639, 2006 Fulton County D. Rep. 1931, 39 Employee Benefits Cas. (BNA) 1186, 2006 Ga. LEXIS 446
CourtSupreme Court of Georgia
DecidedJune 26, 2006
DocketS05G2011
StatusPublished
Cited by4 cases

This text of 632 S.E.2d 95 (Advance PCS v. Bauer) is published on Counsel Stack Legal Research, covering Supreme Court of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Advance PCS v. Bauer, 632 S.E.2d 95, 280 Ga. 639, 2006 Fulton County D. Rep. 1931, 39 Employee Benefits Cas. (BNA) 1186, 2006 Ga. LEXIS 446 (Ga. 2006).

Opinion

Sears, Chief Justice.

We granted certiorari in this case to determine whether the Court of Appeals correctly held that the Employee Retirement Income Security Act of 1974 1 (“ERISA”) did not preempt plaintiffs’ claims. 2 Because plaintiffs’ claims are dependent on the terms of their respective ERISA plans (“plans”), and could have been raised in the context of ERISA’s civil enforcement provisions, we find that plaintiffs’ claims are preempted by ERISA. Accordingly, we reverse.

*640 The plaintiffs are breast cancer survivors who were prescribed the drug tamoxifen over a period of years to reduce the chances of the cancer recurring. The defendant is Advance PCS, Inc. (“PCS”), a pharmaceutical benefits manager that contracted with plaintiffs’ ERISAplan providers to process the prescription drug benefits under the plans. ERISA is a nationally uniform regulatory framework that governs operation and administration of employer-provided health insurance plans, and is “designed to promote the interests of employees and their beneficiaries in employee benefit plans.” 8

Plaintiffs’ ERISAplans include prescription drug benefits, which entitle plaintiffs to obtain prescribed drugs by paying a particular co-payment, and require the plan provider to cover the remaining cost of the drugs. Plaintiffs are required to pay a higher co-payment for brand name drugs than for generic drugs. Plaintiffs claim under Georgia law that PCS was unjustly enriched by improperly classifying tamoxifen as a “brand-name” drug, when it should have been classified as a “generic” drug. Although the terms “generic” and “brand-name” are defined in plaintiffs’ respective plans, PCS used independent classification sources to classify tamoxifen as a brand-name drug. Plaintiffs seek to represent themselves and persons similarly situated in a class under OCGA § 9-11-23.

Although plaintiffs’ plans contain ERISA-mandated internal review procedures by which plaintiffs can appeal adverse benefit determinations, plaintiffs chose not to utilize those internal appeal procedures. Instead, plaintiffs filed a complaint seeking to represent the class of persons for whom PCS classified tamoxifen as a brand name drug “when the medical plans covering [those persons] do not permit [PCS] to classify tamoxifen as a brand name drug.”

1. Express Preemption.

ERISA § 514 (a) 3 4 states that ERISA “shall supersede any and all State laws insofar as they may now or hereafter relate to any employee benefit plan [covered by ERISA].” “Section 514 (a) was intended to ensure that plans and plan sponsors would be subject to a uniform body of benefits law ... [and] to minimize the administrative and financial burden of complying with conflicting directives among States or between States and the Federal Government.” 5 The parties acknowledge that the plans are covered by ERISA, so the plaintiffs’ state law claims are expressly preempted in this case if those claims “relate to” plaintiffs’ ERISAplans. 6

*641 “Congress used the words ‘relate to’ in § 514 (a) in their broad sense.” 7 Acause of action “relates to” a plan where “it has a connection with or reference to such a plan.” 8 The “deliberately expansive” 9 language used in § 514 (a) “indicates Congress’s intent to establish the regulation of employee welfare benefit plans ‘as exclusively a federal concern.’ ” 10

Where a state law tort action is “based on alleged improper processing of a claim for benefits under an employee benefit plan,” 11 that claim absolutely “relates to” the plan. 12 A claim will also be preempted where the terms or existence of the plan is “a critical factor in establishing liability.” 13

Because the plaintiffs’ claims depend entirely on the language of their plans, and whether that language entitles them to pay a generic co-payment for the drug tamoxifen, those claims are expressly preempted by ERISA. As stated in Aetna Health, Inc. v. Davila, plaintiffs’ claims are preempted by ERISA because any liability under those claims “derives entirely from the particular rights and obligations established by the benefits plans.” 14 Plaintiffs’ co-payment responsibility and entitlement exists only because the plans required plaintiffs to pay a specified amount for a generic drug and another amount for a brand name drug. Only if the plan entitles them to the generic co-payment for tamoxifen would their unjust enrichment claims against PCS have any merit.

Plaintiffs attempt to distinguish the cases finding ERISA preemption by arguing that their claims are not based on any improper denial of benefits, as there is no question that their ERISA plans entitle them to obtain tamoxifen generally. That contention, however, takes an unduly narrow view of the definition of “benefit” under an ERISAplan. It is true that plaintiffs’ claims are not the typical “denial of coverage” claims that are ubiquitous in health insurance disputes. *642 But plaintiffs’ right to obtain a drug by paying a particular co-payment, which requires their plan provider to cover the remaining cost of the drug, is undeniably a plan benefit. 15

Plaintiffs also argue that their claims do not “relate to” their ERISA plans because PCS’s classification of tamoxifen as a brand-name drug is not based on the definitions in the plans, but is based instead on independent classification sources. PCS’s reasons for classifying tamoxifen as brand-name, however, are irrelevant to plaintiffs’ entitlements and any unjust enrichment by PCS based on its miscalculation of those entitlements. If plaintiffs are entitled to pay a generic co-payment for tamoxifen, based on the language and definitions of their respective plans, then plaintiffs’ plan providers are obligated to provide the drug at that price regardless of any designation by PCS. If PCS’s classification is deemed erroneous, and the plan providers are ordered to provide the drug as a generic drug, then any liability for the misclassification is a contractual matter between PCS and the plan providers. Whether or not PCS improperly calculated the amount plaintiffs owed for their drugs, the ultimate responsibility for such a decision, with respect to the plaintiffs, lies with the plan administrators.

Next, plaintiffs contend that their claims are not preempted because PCS is not an ERISA fiduciary.

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AdvancePCS v. Bauer
642 S.E.2d 342 (Court of Appeals of Georgia, 2007)
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Cite This Page — Counsel Stack

Bluebook (online)
632 S.E.2d 95, 280 Ga. 639, 2006 Fulton County D. Rep. 1931, 39 Employee Benefits Cas. (BNA) 1186, 2006 Ga. LEXIS 446, Counsel Stack Legal Research, https://law.counselstack.com/opinion/advance-pcs-v-bauer-ga-2006.