Advanced Reimbursement Solutions LLC v. Aetna Life Insurance Company

District Court, D. Arizona·Decided March 25, 2022·No. 2:19-cv-05395·Unknown

Opinion

1 WO 2 3 4 5

9 Advanced Reimbursement Solutions LLC, et No. CV-19-05395-PHX-DLR al., Plaintiffs, 11 v. 12 Aetna Life Insurance Company, et al., 13 Defendants. 14 15 16 Counterclaim-Plaintiffs are Aetna, Inc., and Aetna Life Insurance Company 17 (“Aetna”). Counterclaim-Defendants are Advanced Reimbursement Solutions, LLC 18 (“ARS”), American Surgical Development, LLC (“ASD”), and 9 outpatient treatment 19 centers (“OTCs”).1 Pending before the Court are motions to dismiss Aetna’s Second 20 Amended Counterclaim (“SACC”) filed by ARS and ASD (Doc. 262) and the remaining 21 OTCs (Docs. 274 and 284). Also before the Court is Aetna’s motion for leave to amend 22 its SACC. (Doc. 437.) As explained below, the Court grants in part and denies in part 23 ARS and ASD’s motion to dismiss, denies the remaining OTCs’ motions to dismiss, and 24 grants Aetna’s motion for leave to amend.2

25 1 Aetna named 19 OTCs, but only 9 remain. The remaining OTCs fall into two separately represented groups: (1) Arrowhead Outpatient Treatment Center, LLC; 26 Lakeshore Interventional Treatment Center, LLC; Mesa Outpatient Treatment Center, LLC; Tempe Interventional Treatment Center, LLC; Tempe Outpatient Treatment Center, 27 LLC; and West Valley OTC, LLC (collectively, “Treatment Center OTCs”), and (2) Valley Pain Centers LLC; Valley Pain Centers of Peoria, LLC; and Valley Pain Centers of 28 Arizona, LLC (collectively, “Pain Center OTCs”). 2 Oral argument is denied because the issues are adequately briefed, and oral 1 I. Background3 2 Aetna brings counterclaims on its own behalf as the provider of fully insured health 3 plans, and in its capacity as claims administrator for self-funded, employer-established 4 health plans that retain Aetna as a third-party administrator. For fully insured plans, Aetna 5 pays claims using its own money. For self-funded plans, claims are paid directly by 6 employers and employees using their own money, but in its capacity as claims 7 administrator, Aetna is authorized by contract to bring actions to recover overpayments on 8 behalf of those plans. (Doc. 203-1 ¶¶ 43-49.) 9 Aetna policy and the terms of Aetna’s plans set forth several requirements designed 10 to impose reasonable limits on the cost of care. For example, Aetna members have cost- 11 sharing obligations. (Id. ¶ 53.) Plan members generally are required to pay an annual 12 deductible before plan benefits are triggered. Once members have paid their deductibles, 13 the plans then generally require members to pay coinsurance—a percentage of the cost— 14 for the healthcare services they receive, until they meet a plan-prescribed out-of-pocket 15 maximum. Members also sometimes are required to pay fixed dollar amounts called 16 copays at the time they receive certain healthcare services. (Id. ¶¶ 54-56.) Aetna’s 17 Copayment and Coinsurance Waivers Payment Policy requires providers to collect 18 copayments and coinsurance as defined by a member’s plan and prohibits providers from 19 waiving those obligations. (Id. ¶ 57.) 20 Aetna also controls costs by entering into network contracts with healthcare 21 providers that set rates Aetna will pay for services rendered by the in-network provider. 22 Out-of-network providers, by contrast, have not agreed to a particular reimbursement for 23 their services and therefore can charge more that in-network providers. (Id. ¶ 60.) But to 24 discourage members from obtaining care from more expensive, out-of-network providers, 25 Aetna typically imposes on members higher coinsurance obligations for out-of-network 26 services, and Aetna members are responsible for the difference between what the out-of-

27 argument will not aid the Court’s decision-making. See Fed. R. Civ. P. 78(b); LRCiv. 7.2(f). 28 3 The following facts are derived from Aetna’s SACC and presumed true for purposes of this order. 1 network provider bills Aetna and the amount allowed by Aetna. (Id. ¶¶ 61-62.) 2 The OTCs contracted with ARS and ASD to provide, among other things, billing 3 services and back-office support in exchange for a portion of the OTCs’ reimbursements. 4 (Id. ¶¶ 66-81.) Aetna alleges that Counterclaim-Defendants “engag[ed] in a multi-faceted 5 out-of-network billing scheme intended to extract extraordinarily inflated payments from 6 Aetna and its self-funded plan sponsors simply because Aetna members received treatment 7 from medical professionals at the OTCs’ offices.” (Id. ¶ 1.) In particular, Aetna accuses 8 Counterclaim-Defendants of: 9 (a) causing Aetna’s contracted providers to refer patients to the out-of-network OTCs in violation of their provider contracts; 10 (b) causing in-network providers to perform services at out-of- network OTCs in violation of their contracts; (c) inducing 11 Aetna members to violate the terms of their insurance plans, including by waiving the Aetna members’ cost-sharing 12 obligations, which otherwise would have served as a deterrent to Aetna members’ use of the OTCs; (d) improperly billing for 13 facility fees on behalf of the OTCs, including misrepresenting the licensure and nature of the OTCs, despite the fact that 14 industry-standard practices and Aetna policy prohibited the billing of facility fees by OTCs; (e) misrepresenting the OTCs’ 15 rates and instead billing at rates required by ARS, which artificially inflated the OTCs’ charges by up to 4,900%; (f) 16 misrepresenting the medical services actually rendered to Aetna members; and (g) billing for uncovered and 17 experimental medical treatments. 18 (Id. ¶ 83.) 19 Aetna’s detailed, 336-paragraph SACC contains 13 separate claims: (1) tortious 20 interference with its Member Benefit Plans, brought against all Counterclaim-Defendants; 21 (2) tortious interference with its Provider Contracts, brought against all Counterclaim- 22 Defendants; (3) fraud, brought against all Counterclaim-Defendants; (4) negligent 23 misrepresentation, brought against all Counterclaim-Defendants; (5) violations of the 24 federal Racketeer Influenced and Corrupt Organizations (“RICO”) Act, 18 U.S.C. § 25 1962(c), brought against ARS and ASD only; (6) violation of RICO, 18 U.S.C. § 1962(d), 26 brought against ARS and ASD only; (7) violation of Arizona’s version of RICO, A.R.S. § 27 13-2314.01, brought against ARS and ASD only; (8) conspiracy to violate Arizona’s RICO 28 statute, brought against ARS and ASD only; (9) civil conspiracy, brought against all 1 Counterclaim-Defendants; (10) aiding and abetting a tort, brought against all 2 Counterclaim-Defendants; (11) for recoupment of overpayments under the Employee 3 Retirement Income Security Act (“ERISA”), 29 U.S.C. § 1132(a)(3), brought against all 4 Counterclaim-Defendants; (12) unjust enrichment, brought against all Counterclaim- 5 Defendants; and (13) money had and received, brought against all Counterclaim 6 Defendants. (Doc. 203-1.) 7 II. Legal Standard 8 The Federal Rules of Civil Procedure require a pleading to contain “a short and plain 9 statement of the claim showing that the pleader is entitled to relief[.]” Fed. R. Civ. P. 10 8(a)(2). “To avoid a Rule 12(b)(6) dismissal, a complaint need not contain detailed factual 11 allegations; rather, it must plead ‘enough facts to state a claim to relief that is plausible on 12 its face.’” Clemens v.

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