American Economy Insurance Company v. Accelerated Rehabilitation Centers, Ltd

2022 IL App (1st) 211410-U
CourtAppellate Court of Illinois
DecidedSeptember 30, 2022
Docket1-21-1410
StatusUnpublished
Cited by2 cases

This text of 2022 IL App (1st) 211410-U (American Economy Insurance Company v. Accelerated Rehabilitation Centers, Ltd) is published on Counsel Stack Legal Research, covering Appellate Court of Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
American Economy Insurance Company v. Accelerated Rehabilitation Centers, Ltd, 2022 IL App (1st) 211410-U (Ill. Ct. App. 2022).

Opinion

2022 IL App (1st) 211410-U No. 1-21-1410 Third Division September 30, 2022

NOTICE: This order was filed under Supreme Court Rule 23 and is not precedent except in the limited circumstances allowed under Rule 23(e)(1). ______________________________________________________________________________

IN THE APPELLATE COURT OF ILLINOIS FIRST DISTRICT ______________________________________________________________________________

AMERICAN ECONOMY INSURANCE COMPANY, ) AMERICAN FIRE AND CASUALTY COMPANY, ) Appeal from the Circuit Court AMERICAN STATES INSURANCE COMPANY, ) of Cook County. CONSOLIDATED INSURANCE COMPANY, ) EMPLOYERS INSURANCE COMPANY OF WAUSAU, ) No. 20 L 13373 FIRST NATIONAL INSURANCE COMPANY OF ) AMERICA, HELMSMAN MANAGEMENT SERVICES ) The Honorable LLC, INDIANA INSURANCE COMPANY, LIBERTY ) Diane M. Shelley, INSURANCE CORPORATION, LIBERTY MUTUAL ) Judge Presiding. FIRE INSURANCE COMPANY, LIBERTY MUTUAL ) INSURANCE COMPANY, LM INSURANCE ) CORPORATION, OHIO SECURITY INSURANCE ) COMPANY, PEERLESS INSURANCE COMPANY, ) THE FIRST LIBERTY INSURANCE CORPORATION, ) THE NETHERLANDS INSURANCE COMPANY, THE ) OHIO CASUALTY INSURANCE COMPANY, ) WAUSAU BUSINESS INSURANCE COMPANY, ) WAUSAU UNDERWRITERS INSURANCE COMPANY, ) and WEST AMERICAN INSURANCE COMPANY, ) Plaintiffs-Appellees, ) ) v. ) ) ACCELERATED REHABILITATION CENTERS, LTD., ) Individually and d/b/a Newsome Physical Therapy, Premier) Physical Therapy Services, Athletico Physical Therapy ) ARC, and Occucare, and ATHLETICO, LTD, Individually ) and d/b/a Athletico Physical Therapy, Sports Physical ) Therapy, Prorehab, PC., and Occucare, ) Defendants-Appellants. ) ______________________________________________________________________________ No. 1-21-1410

JUSTICE REYES delivered the judgment of the court. Presiding Justice McBride and Justice Burke concurred in the judgment.

ORDER

¶1 Held: The circuit court properly denied defendants’ motion to dismiss or, in the alternative, to compel arbitration where the plaintiffs were not signatories to the contracts that contained arbitration clauses, nor did an exception apply that would operate to bind them to the contracts.

¶2 The instant appeal arises from a lawsuit filed by plaintiffs, a group of insurance companies

all doing business under the trade name of Liberty Mutual Insurance, against defendants,

Accelerated Rehabilitation Services, Ltd., and Athletico, Ltd., two physical therapy providers. 1

In their complaint, plaintiffs alleged that defendants fraudulently submitted bills based on

services that defendants did not actually provide, which plaintiffs paid. Defendants filed a

motion to dismiss the complaint pursuant to section 2-619 of the Code of Civil Procedure

(Code) (735 ILCS 5/2-619 (West 2020)) or, in the alternative, to compel arbitration, claiming

that an arbitration clause contained in defendants’ contracts with third-party administrators

governed plaintiffs’ claims. The circuit court denied the motion to dismiss, and defendants

filed an interlocutory appeal under Illinois Supreme Court Rule 307(a)(1) (eff. Nov. 1, 2017).

For the reasons that follow, we affirm the judgment of the circuit court.

¶3 BACKGROUND

¶4 Plaintiffs are a group of insurance companies which provide workers’ compensation

policies for certain employers. Between 2011 and 2020, a number of employees of these

employers sought physical therapy services from defendants after suffering work-related

injuries, and plaintiffs paid the bills submitted by defendants in connection with these services.

1 According to plaintiffs’ complaint, defendant Athletico, Ltd., acquired defendant Accelerated Rehabilitation Services, Ltd., and all of its brands in 2014. 2 No. 1-21-1410

¶5 In December 2020, plaintiffs filed a four-count complaint against defendants for fraud and

negligent misrepresentation, alleging that their investigations had revealed “fraudulent

deviations” from proper coding rules with respect to billing, which resulted in “substantial

overpayments” to defendants. Specifically, plaintiffs alleged that defendants billed plaintiffs

by using codes that required skilled direct patient contact in circumstances when those services

were not provided.

¶6 Defendants filed a combined motion to dismiss the complaint pursuant to section 2-619.1

of the Code (735 ILCS 5/2-619.1 (West 2020)), claiming that plaintiffs’ complaint was vague

and failed to provide sufficient detail to identify specific instances of alleged fraud, including

when and where they allegedly occurred. The circuit court granted defendants’ motion in part,

dismissing three of the counts without prejudice and with leave to amend.

¶7 Plaintiffs filed an amended complaint in June 2021; while their complaint was

substantively similar to their prior complaint, they also included 50 specific examples of

defendants’ allegedly improper billing. In addition, as in their original complaint, plaintiffs

attached over 2000 pages of exhibits consisting of spreadsheets containing data as to the

amounts paid by plaintiffs for each code at issue. 2

¶8 Defendants filed a motion to dismiss the amended complaint under section 2-619 of the

Code or, in the alternative, to compel arbitration. Defendants claimed that they had investigated

the 50 specific claims that plaintiffs identified in the amended complaint, and at least 25 of

those claims were submitted for payment pursuant to agreements containing mandatory

2 The entries on the spreadsheets do not contain any identifying information as to the patient or the location of the physical therapy clinic, but include only claim numbers, dates of service, the codes charged, and the amounts billed and paid. We note that most of the spreadsheets contained in the record on appeal are cut off at one end, meaning that the column including claim numbers is not included. 3 No. 1-21-1410

arbitration provisions. Defendants contended that they had entered into those agreements with

various third-party administrators (TPAs) which acted as plaintiffs’ agents and plaintiffs were

thereby bound by the provisions in the agreements.

¶9 In support, defendants submitted the affidavit of Beth Trubich (Trubich), a senior manager

of billing for defendants, who averred that payors such as plaintiffs regularly contract with

TPAs to assist with their responsibilities in processing patient claims and payments to health

care providers. In turn, defendants contracted with such TPAs, acting as agents on behalf of

the payors, in connection with their services. As part of these contracts, defendants agreed to

provide their services to the payors’ members at significantly lower reimbursement rates.

Trubich averred that “[o]n information and belief, Payors authorized various TPAs to enter

into agreements with [defendants] for these lower reimbursement rates.” Trubich further

averred that when defendants negotiated with TPAs, all parties were aware that they were

negotiating with entities acting on behalf of the payors. With respect to plaintiffs in the instant

case, Trubich averred that, “[u]pon information and belief, the Plaintiffs in this case are all

Payors that have contracts with [defendants] through various TPAs to provide health care

services to their members at significantly discounted rates.” Specifically, Trubich identified 26

claims listed in plaintiffs’ amended complaint that were processed pursuant to defendants’

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Related

In re Estate of Dukes
2025 IL App (5th) 240645 (Appellate Court of Illinois, 2025)

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Bluebook (online)
2022 IL App (1st) 211410-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/american-economy-insurance-company-v-accelerated-rehabilitation-centers-illappct-2022.