Advanced Risk Managers, LLC v. Equinox Management Group, Inc.

CourtDistrict Court, N.D. California
DecidedSeptember 17, 2021
Docket4:19-cv-03532
StatusUnknown

This text of Advanced Risk Managers, LLC v. Equinox Management Group, Inc. (Advanced Risk Managers, LLC v. Equinox Management Group, Inc.) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Advanced Risk Managers, LLC v. Equinox Management Group, Inc., (N.D. Cal. 2021).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 ADVANCED RISK MANAGERS, LLC, Case No. 19-cv-03532-DMR

8 Plaintiff, ORDER ON MOTION FOR SUMMARY 9 v. JUDGMENT

10 EQUINOX MANAGEMENT GROUP, Re: Dkt. No. 87 INC., 11 Defendant. 12 13 Plaintiff Advanced Risk Managers, LLC (“ARM”) filed this breach of contract action 14 against Defendant Equinox Management Group, Inc. (“Equinox”). Equinox now moves for 15 summary judgment. [Docket No. 87.] This matter is suitable for resolution without a hearing. 16 Civ. L.R. 7-1(b). For the following reasons, the motion is denied. 17 I. BACKGROUND 18 A. Factual Background 19 This contract dispute involves Equinox’s alleged failure to pay ARM, a consulting 20 company that offers medical claims review services for insurance and reinsurance companies. 21 [Docket No. 96-1 (Pfeffer Decl., Feb. 18, 2021) ¶ 2, Ex. 1 (Choi Dep.) 17.] Equinox’s services 22 include facilitating claims management between insurance companies and its reinsurer clients. 23 Pfeffer Decl. ¶ 4, Ex. 3 (McAndrew Dep.) 16-19.] One of Equinox’s clients is third-party 24 Renaissance Reinsurance U.S. Inc. (“RenRe”), a reinsurance company that issues coverage to 25 health insurance companies. [See Docket No. 90 (McAndrew Decl., Feb. 4, 2021) ¶ 4.] 26 RenRe hired Equinox as the Managing General Underwriter to manage reinsurance claims 27 from insurance companies on its behalf. McAndrew Decl. ¶ 3. This included RenRe’s 1 Health Plan (“Geisinger”), and Louisiana Health Cooperative, Inc. (“LAHC”). Id. Equinox’s role 2 included paying small claims on behalf of RenRe, compiling documentation, investigating claims, 3 and facilitating negotiations of claims between RenRe and the insureds. McAndrew Dep. 113-15; 4 Pfeffer Decl. ¶ 5, Ex. 4 (Morr Dep.) 19. Equinox would review Humana and Geisinger claims and 5 make payment recommendations to RenRe. Pfeffer ¶ 3, Ex. 2 (Philipps Dep.) 33-35. RenRe 6 employees Gerry Morr or Samantha Engel would then instruct Equinox to pay, deny, or take other 7 action on the claims. Id. at 36. 8 The Humana and Geisinger reinsurance treaties involved large claims that required 9 “someone who specializes in reviewing hospital bills and large catastrophic charges to … 10 determine whether the charges were proper[].” Equinox was not able to perform that work by 11 itself. Philipps Dep. 40, 42-43. In 2015, RenRe’s Engel recommended that Equinox retain ARM 12 to assist in that work, after having reviewed claim review samples provided by ARM’s president 13 Mimi Choi. Pfeffer Decl. ¶ 6, Ex. 5 (Engel Dep.) 77, 80-81; Philipps Dep. 40. 14 1. ARM’s Agreement with Equinox 15 On September 3, 2015, Equinox and ARM executed an Agreement for Consulting Services 16 under which ARM would perform claims review services for Equinox. [Docket Nos. 89 (Cross 17 Decl., Feb. 4, 2021) ¶ 35, Ex. 23 (the “Agreement”); Ex. 4 (Choi Decl., Oct. 8, 2019) ¶ 8.] It lists 18 Norbert Phillipps, Equinox Claims Account Manager, as the Equinox “Company Representative.” 19 Agreement; McAndrew Dep. 71. Equinox and ARM are the only parties to the Agreement. 20 However, RenRe reimbursed Equinox for the cost of ARM’s services. McAndrew Dep. 68; Cross 21 Decl. ¶ 17, Ex. 5. Multiple individuals at both Equinox and RenRe reviewed and approved the 22 Agreement prior to its execution. Philipps Dep. 51-52; McAndrew Dep. 67-68; Engel Dep. 89-90; 23 Morr Dep. 51-52. 24 Pursuant to the Agreement, ARM reviewed hospital bills on behalf of RenRe. According 25 to Equinox, ARM reviewed the hospital bills and prepared “report[s] challenging potentially 26 invalid charges;” RenRe would then use the reports “to assess whether insurers were paying 27 claims appropriately, and potentially in seeking to reduce the amount it was required to 1 The Agreement states that “[f]or each assignment” that Equinox gave to ARM, the parties 2 were to “draft a Description of Services . . . that describes the services that ARM will perform and 3 the items that ARM will deliver (the ‘Services’); the schedule or duration of the Services; and the 4 fees that [Equinox] will pay in return.” Agreement ¶ 1. It further provides that “[i]n order for 5 ARM to perform the services effectively, [Equinox] will provide ARM with information and tools 6 that are listed in the Description of Services.” Id. Exhibit A to the Agreement, titled “Description 7 of Services,” is expressly incorporated into the Agreement. Agreement ¶ 1, Ex. A (Description of 8 Services). 9 The Description of Services states that ARM will provide certain services to Equinox, only 10 one of which is at issue here. ARM’s “Large Claims Integrity Review and Negotiation” service 11 “focused on maximized claims savings and cost utilization through diligent large claims billing 12 accuracy and appropriateness review.” It encompasses two categories: 1) “Pre-payment Review 13 and Negotiation,” which occurs when the medical provider has not yet been paid for their services; 14 and 2) “Post Payment Claims Review,” which involves claims where the medical provider has 15 already been paid. Description of Services § I(B); Choi Dep. 78; Phillipps Dep. 53-54. It is 16 undisputed that the claims in this case all fall within the “Post Payment Claims Review” category. 17 Choi Dep. 77-78; McAndrew Dep. 103; Phillipps Dep. 54. 18 The Description of Services provides that ARM would review the itemized bills to identify 19 problems such as duplicates, errors, “[o]ff label or experimental protocols,” “[p]harmaceuticals 20 billed in excess of manufacturer’s recommended dosages,” and situations where there is “[n]o 21 supporting diagnosis or surgical procedure for billed items.” ARM would then provide Equinox 22 with “a review summary” upon completion of the review. Description of Services § I(B). 23 As to payment for ARM’s services, there are two bullet points under the “Fees” section for 24 post payment claims review:

25 • For internal claims reference only and no claims reduction will be applied, this service is billed at $195/hour. 26 • When the review is used to facilitate post-payment adjudication, 27 settlement, or resolution of the claim, this service is billed at 28% 1 Id. The Agreement also contains a provision about the payment process:

2 3.1. Invoice. ARM shall invoice [Equinox] at the end of each calendar month in accordance with the fees and expenses as set forth 3 in the Description of Services.

4 3.2. Payment. Payment on the invoices is due and payable within Twenty (15) [sic] days of [Equinox’s] receipt of the invoice. ARM 5 invoices shall be sent to the address and individual set forth in the Description of Services. 6 Agreement § 3. 7 Choi testified that when Equinox first sent her claims to review, she assumed it was for 8 “internal” use only, to be billed at ARM’s hourly rate. Choi Dep. 64-65, 109, 115-16. Through 9 the course of its work under the Agreement, ARM submitted hourly invoices under the “internal 10 claims reference only” provision, billed at the $195 hourly rate. McAndrew Decl. ¶ 6; Choi Dep. 11 109. ARM never invoiced Equinox under the “28% of net claims reduction savings” provision. 12 Choi Dep. 108-09, 116. It is undisputed that Equinox fully paid all of ARM’s invoices for hourly 13 work. See McAndrew Decl. ¶ 6. 14 2. ARM’s Agreement with RenRe, Subsequent Lawsuit, and October 15 2018 Settlement 16 In 2017, RenRe started sending some work directly to ARM, instead of passing the work to 17 ARM through Equinox. On May 22, 2017, ARM executed an Agreement for Consulting Services 18 with RenRe. Cross Decl. Ex. 36 (RenRe Agreement). It listed Morr as the RenRe company 19 representative. Id. The RenRe Agreement is nearly identical to the ARM/Equinox Agreement, 20 and contains an identical fee provision:

21 • For internal claims reference only and no claims reduction will be 22 applied, this service is billed at $195/hour.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Anderson v. Liberty Lobby, Inc.
477 U.S. 242 (Supreme Court, 1986)
Scott v. Harris
550 U.S. 372 (Supreme Court, 2007)
Waller v. Truck Insurance Exchange, Inc.
900 P.2d 619 (California Supreme Court, 1995)
Producers Dairy Delivery Co. v. Sentry Insurance
718 P.2d 920 (California Supreme Court, 1986)
Henry v. Sharma
154 Cal. App. 3d 665 (California Court of Appeal, 1984)
Bennett v. Carlen
213 Cal. App. 2d 307 (California Court of Appeal, 1963)
WYDA Associates v. Merner
42 Cal. App. 4th 1702 (California Court of Appeal, 1996)
Winet v. Price
4 Cal. App. 4th 1159 (California Court of Appeal, 1992)
Fox v. Ethicon Endo-Surgery, Inc.
110 P.3d 914 (California Supreme Court, 2005)
Centigram Argentina., S.A. v. Centigram Inc.
60 F. Supp. 2d 1003 (N.D. California, 1999)
Zimmermann v. Miller
2 F.2d 623 (S.D. New York, 1924)
Aguilera v. Pirelli Armstrong Tire Corp.
223 F.3d 1010 (Ninth Circuit, 2000)
Buschman v. Anesthesia Business Consultants LLC
42 F. Supp. 3d 1244 (N.D. California, 2014)

Cite This Page — Counsel Stack

Bluebook (online)
Advanced Risk Managers, LLC v. Equinox Management Group, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/advanced-risk-managers-llc-v-equinox-management-group-inc-cand-2021.