Advanced Gynecology & Laparascopy of North Jersey v. Cigna Health & Life Insurance Co

Court of Appeals for the Third Circuit·Decided July 13, 2026·No. 24-2212·Unpublished

Opinion

UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT No. 24-2212

ADVANCED GYNECOLOGY AND LAPAROSCOPY OF NORTH JERSEY P.C.; AESTHETIC & RECONSTRUCTIVE SURGEONS, LLC; ATLANTIC PEDIATRIC ORTHOPEDICS PA; BERGEN SURGICAL SPECIALISTS P.A.; EAST COAST AESTHETIC SURGERY P.C., et al., Appellants

v.

CIGNA HEALTH AND LIFE INSURANCE COMPANY; CONNECTICUT GENERAL LIFE INSURANCE COMPANY

_____________________________ Appeal from the U.S. District Court, D.N.J. Judge Esther Salas, No. 2:19-cv-22234

Before: SHWARTZ, FREEMAN, and RENDELL, Circuit Judges Submitted Jul. 7, 2025; Decided Jul. 13, 2026 _____________________________

NONPRECEDENTIAL OPINION *

FREEMAN, Circuit Judge.

New Jersey-based healthcare practices appeal the dismissal of their ERISA, RICO,

and state law claims against insurance providers. We will AFFIRM the dismissal of the state

law claims and most ERISA fiduciary-duty claims. However, when construed in the light

most favorable to the plaintiffs, the operative complaint states claims for some ERISA

* This disposition is not an opinion of the full Court and, under I.O.P. 5.7, is not binding precedent. violations, so we will VACATE the dismissal of those claims. We also will VACATE the

dismissal of the RICO claims, and we will REMAND this matter for further proceedings.

I

Plaintiffs are nearly two dozen New Jersey-based healthcare practices (the

“Practices”). The Practices provide out-of-network healthcare services to subscribers of

health-insurance carriers Cigna Health and Life Insurance Company and Connecticut

General Life Insurance Company (collectively, “Cigna”). 1 The Practices allege that Cigna

has underpaid them for thousands of out-of-network elective and emergency claims, in

violation of the terms of Cigna’s insurance plans (the “Plans”). 2 Specifically, they claim

Cigna was required to reimburse the Practices for covered expenses at the rates specified

in the Plans for out-of-network providers. Particularly relevant to those rates is the

Maximum Reimbursable Charge (“MRC”), which is used to calculate reimbursements for

different types of services the hospitals provided.

1. Elective treatment

For elective treatment, each Plan required Cigna to calculate reimbursement to

out-of-network providers based on one of two methods: MRC-1 or MRC-2. Ultimately,

1 “Out-of-network” providers are those that do not have contracts with insurance providers to accept pre-negotiated rates. 2 When Cigna subscribers seek treatment from the Practices, they “assign their rights to benefits under the Cigna Plans to [the Practices].” App. 91. This means that the Practices may seek reimbursement directly from Cigna, instead of billing the subscribers who would then seek reimbursement from Cigna. See N. Jersey Brain & Spine Ctr. v. Aetna, Inc., 801 F.3d 369, 372 (3d Cir. 2015) (“[A]ssignment of the right to payment logically entails the right to sue for non-payment.”). Cigna does not argue that any anti- assignment provisions bar this suit.

2 Cigna was required to pay the Practices the relevant MRC value, less any applicable co-

insurance, co-payments, or deductibles.

MRC-1. Plans utilizing the MRC-1 method for calculating reimbursements include

language substantially similar to the following:

The Maximum Reimbursable Charge for covered services is determined based on the lesser of:

• the provider’s normal charge for a similar service or supply;

or

• a policyholder-selected percentile of charges made by providers of such service or supply in the geographic area where it is received as compiled in a database selected by [Cigna].

The percentile used to determine the Maximum Reimbursable Charge is listed in The Schedule.

App. 115–16.

The Practices allege, based on preliminary discovery, that the “database selected

by Cigna,” as referenced in the MRC-1 method, is the FAIR Health database. App. 116. 3

They further allege that all of the MRC-1 plans at issue reimburse out-of-network

providers at an amount between the 80th and 100th percentile of the FAIR Health

database.

The Practices explain they “typically set their normal charges at or around the 80th

percentile of the Fair Health database” so “in most if not all cases, Plaintiffs’ normal

3 The Fair Health database uses information from billions of claims to estimate what medical providers charge, and what insurers pay, for providing healthcare to patients.

3 charges for each service or supply represent the MRC-1 amount.” App. 92. Thus, the

MRC-1 method should have resulted in reimbursement near the Practices’ normal

charges. However, for the MRC-1 claims at issue here, reimbursements to the Practices

have averaged just 15.2% of their normal charges.

MRC-2. Plans using the MRC-2 method use language substantially similar to the

following:

The Maximum Reimbursable Charge for covered services is determined based on the lesser of:

• the provider’s normal charge for a similar service or supply;

• a policyholder-selected percentage of a schedule developed by Cigna that is based upon a methodology similar to a methodology utilized by Medicare to determine the allowable fee for the same or similar service within the geographic market.

App. 117–18. We will refer to this as the “first MRC-2 approach.” Those plans also

provide a second way to calculate the MRC-2 amount (the “second MRC-2 approach”):

[I]n some cases, a Medicare based schedule will not be used and the Maximum Reimbursable Charge for covered services is determined based on the lesser of:

• the provider’s normal charge for a similar service or supply;

• the 80th percentile of charges made by providers of such service or supply in the geographic area where it is received as compiled in a database selected by Cigna.

App. 118 n.6 (internal quotation marks omitted).

The Practices allege that Cigna has never developed the Medicare-based schedule

4 referenced in the first MRC-2 approach. Thus, the Practices allege that the MRC-2

method requires reimbursements to be calculated based on their normal charges, less any

patient responsibility. However, for the MRC-2 claims at issue here, reimbursements to

the Practices have averaged just 7.5% of their normal charges. App. 154.

2. Emergency claims The Practices also allege that Cigna failed to appropriately reimburse them for

emergency treatment that they provided to Cigna subscribers. The Plans include

Out-of-Network Emergency Services Charges

1. Emergency services are covered at the In-Network cost- sharing level if services are received from a non- participating (Out-of-Network) provider.

2. The allowable amount used in determining benefit payments for covered emergency services provided in the emergency department of a non-participating (Out-of- Network) Hospital is the negotiated amount agreed to by the Out-of-Network provider and Cigna, or if no amount is agreed upon, the greater of the following:

(i) the median amount negotiated with In-Network providers for the emergency service (excluding In- Network copay or coinsurance);

(ii) the Maximum Reimbursable Charge; or

(iii) the amount payable under the Medicare program (not to exceed the provider’s billed charges).

The member is responsible for the applicable In-Network cost- sharing amounts.

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Advanced Gynecology & Laparascopy of North Jersey v. Cigna Health & Life Insurance Co, (3d Cir. 2026).

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