AETNA LIFE INSURANCE COMPANY v. MAXIMUM MEDICAL & REHABILITATION

CourtDistrict Court, D. New Jersey
DecidedApril 23, 2025
Docket2:24-cv-10362
StatusUnknown

This text of AETNA LIFE INSURANCE COMPANY v. MAXIMUM MEDICAL & REHABILITATION (AETNA LIFE INSURANCE COMPANY v. MAXIMUM MEDICAL & REHABILITATION) is published on Counsel Stack Legal Research, covering District Court, D. New Jersey primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
AETNA LIFE INSURANCE COMPANY v. MAXIMUM MEDICAL & REHABILITATION, (D.N.J. 2025).

Opinion

NOT FOR PUBLICATION

UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY

: AETNA LIFE INSURANCE COMPANY, : : Civil Action No. 24-10362 (SRC) Plaintiff, : : v. : OPINION & ORDER : MAXIMUM MEDICAL & : REHABILITATION, LLC, DR. JAMES : MORALES, and JOHN DOES 1-20 : : Defendants. :

CHESLER, District Judge This matter comes before the Court on Defendants Maximum Medical & Rehabilitation, LLC (“MMR”) and Dr. James Morales’ (“Dr. Morales,” and together with MMR, “Defendants”) motion to dismiss the Amended Complaint under Federal Rules of Civil Procedure 12(b)(1) and 12(b)(6), (Dkt. No. 17). Plaintiff Aetna Life Insurance Company, Inc. (“Aetna” or “Plaintiff”) opposed the motion. The Court heard oral argument on the motion on March 19, 2025. For the reasons set forth below, the motion will be GRANTED in part and DENIED in part. I. FACTUAL BACKGROUND This case arises out of allegations that Defendants engaged in a fraudulent and/or improper billing scheme to recoup “at least $567,9624.73” in payments from Plaintiff by submitting claims that contained false or misleading information regarding “facility fees” that Defendants were not entitled to. Aetna insures and administers commercial and governmental health benefit plans to private employers and government entities. (Dkt. No. 15 (“Am. Compl.”) ¶ 14.) Defendant MMR is “a physical medicine and rehabilitation facility.” (Id. ¶ 9.) Defendant Dr. Morales is a New Jersey physician and the medical director of MMR. (Id. ¶ 10.) To obtain payment for services from Plaintiff, healthcare providers, like Defendants, submit health insurance claims using “standard billing forms.” (Id. ¶ 15.) These standard billing

forms require providers to use numerical codes to describe the service the healthcare provider rendered. (Id.) Plaintiff uses billing forms to determine whether a service is covered and if so, the appropriate amount of payment owed to the healthcare provider. (Id. ¶ 16.) Plaintiff names one type of billing form in the Amended Complaint, a UB-04 form,1 and attaches as exhibits certain unnamed digital claim forms2 that Defendants used to perpetrate their alleged scheme. (Id. ¶¶ 25–27, 35, 44.) From June 2022 to at least June 2023, MMR submitted claims to Aetna for professional fees, identifying Dr. Morales as the healthcare provider, and separate facility fees, in addition to other claims related to the same set of services. (Id. ¶¶ 23– 24.) According to Plaintiff, “[f]acility fees consist of fees charged, often by hospitals and hospital based-facilities (such as outpatient clinics that are owned by a hospital), and cover overhead costs

such as equipment, space, and support staff.” (Id. ¶ 20.) Facility fees “are not reimbursable for office-based services unless they are licensed by the State of New Jersey or Medicare certified.” (Id. ¶ 28.) An ambulatory surgical center (“ASC”), for example, is eligible for a facility fee, but only under certain conditions such as whether the ASC is licensed as such by the State of New Jersey or is Medicare-certified. (Id. ¶¶ 21, 28.) The New Jersey Department of Health defines “Ambulatory Surgery” as “a surgical facility in which ambulatory surgical cases are performed

1 (See Dkt. No. 17 (“Mot.”), Ex. C.) 2 (See Am. Compl., Ex. C & Ex. D.) and which is licensed as an ambulatory surgery facility, separate and apart from any other facility license.” (Id. ¶ 22.) MMR has one licensed ASC that meets the State’s definition that is located at 90 Route 10, West Succasunna, New Jersey 07876. (Id. ¶¶ 5, 34.) Plaintiff, however, alleges that on at least 550 separate occasions, Defendants submitted

claims for services that “[u]pon information and belief,” were “being provided in fitness centers, chiropractic offices, and/or physical therapy centers.” (Id. ¶¶ 27–28.) Plaintiff asserts that the locations where services were actually rendered “were neither licensed by the State of New Jersey nor Medicare certified.” (Id. ¶ 28.) The claim forms Plaintiff received from Defendants allegedly used the licensed Succasunna address regardless of where the services were provided because it is the one MMR facility with an ambulatory surgery facility license.3 (Id. ¶ 34.) Most of the disputed claims also contain a Place of Service (“POS”) Code of 24 (Surgery Center), and include Revenue Codes of 360 (Operating Room Services) and 490 (Ambulatory Surgery Care), “even though none of the treatment associated with the disputed claims was administered in an operating room or an ambulatory surgery center.” (Id. ¶¶ 31, 35.)

By using the address of MMR’s licensed ASC and the above POS and Revenue Codes on their claims, Defendants were able to make it appear to Plaintiff that they were entitled to separate facility fees. (Id. ¶ 53.) Plaintiff, in relying on the contents of Defendants’ claims, determined that Defendants’ claims for separate facility fees were reimbursable, and reimbursed Defendants accordingly. (Id. ¶¶ 67, 70–74, 81–82, 87–88.) Through this alleged scheme of submitting deceptive claim forms, Aetna paid Defendants “at least $567,924.73” for facility fees they were not entitled to “in reasonable and foreseeable

3 The Court notes that Plaintiff did not provide any true and correct copies of actual UB-04 forms Defendant MMR submitted. reliance upon the misrepresentations in the false health insurance claims they submitted.” (Id. ¶ 56.) II. PROCEDURAL HISTORY Plaintiff initiated this matter on November 7, 2024 alleging claims for (I) Violating the

New Jersey Insurance Fraud Prevention Act, (II) Common Law Fraud, (III) Negligent Misrepresentation, and (IV) Unjust Enrichment. On December 18, 2024, Defendants filed a motion to dismiss and to stay discovery in this matter. On January 8, 2025, Plaintiffs filed an amended complaint (the “Amended Complaint”) asserting the same four claims alleged in its initial complaint, (Dkt. No. 15). On February 5, 2025, Defendants filed a motion to dismiss the Amended Complaint and stay discovery (the “Motion”), (Dkt. No. 17). Plaintiff filed an opposition to Defendants’ Motion on March 3, 2025, (Dkt. No. 21). Defendants filed a reply brief in further support of their Motion on March 10, 2025, (Dkt. No. 22). The parties appeared before the Court to be heard on this Motion on March 19, 2025. Through their Motion, Defendants argue that the Amended Complaint should be dismissed in its entirety under Federal Rules of Civil Procedure

12(b)(1) and 12(b)(6), and further, that Counts I–III should be dismissed for failing to meet the heightened pleading requirements of Federal Rule of Civil Procedure 9(b). III. LEGAL STANDARD Under Federal Rule of Civil Procedure 12(b)(1), a court must grant a motion to dismiss if it lacks subject matter jurisdiction to hear a claim. “A motion to dismiss for want of standing is . . . properly brought pursuant to Rule 12(b)(1), because standing is a jurisdictional matter.” Ballentine v. United States, 486 F.3d 806, 810 (3d Cir. 2007). In evaluating a Rule 12(b)(1) motion to dismiss, the Court must first determine whether the motion “presents a ‘facial’ attack or a ‘factual’ attack on the claim at issue, because that distinction determines how the pleading must be reviewed.” Const. Party of Pa. v. Aichele, 757 F.3d 347, 357 (3d Cir. 2014).

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AETNA LIFE INSURANCE COMPANY v. MAXIMUM MEDICAL & REHABILITATION, Counsel Stack Legal Research, https://law.counselstack.com/opinion/aetna-life-insurance-company-v-maximum-medical-rehabilitation-njd-2025.