Brainbuilders, LLC v. Optum, Inc.

CourtNew Jersey Superior Court Appellate Division
DecidedApril 19, 2024
DocketA-0621-22
StatusUnpublished

This text of Brainbuilders, LLC v. Optum, Inc. (Brainbuilders, LLC v. Optum, Inc.) is published on Counsel Stack Legal Research, covering New Jersey Superior Court Appellate Division primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Brainbuilders, LLC v. Optum, Inc., (N.J. Ct. App. 2024).

Opinion

NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ." Although it is posted on the internet, this opinion is binding only on the parties in the case and its use in other cases is limited. R. 1:36-3.

SUPERIOR COURT OF NEW JERSEY APPELLATE DIVISION DOCKET NO. A-0621-22

BRAINBUILDERS, LLC,

Plaintiff-Appellant,

v.

OPTUM, INC., OPTUM SERVICES, INC., OPTUMHEALTH HOLDINGS, LLC, OPTUMHEALTH FINANCIAL SERVICES, INC., OPTUMHEALTH CARE SOLUTIONS, LLC, OPTUMHEALTH CARE SOLUTIONS, INC., OXFORD HEALTH INSURANCE, INC., OXFORD HEALTH PLANS (NY), INC., OXFORD HEALTH PLANS (NJ), INC., OXFORD HEALTH PLANS LLC, UNITEDHEALTHCARE SERVICES, LLC, UNITEDHEALTH GROUP, INC., UNITEDHEALTHCARE SERVICES, INC., UHIC HOLDINGS, INC., UNITED BEHAVIORAL HEALTH, and UNITEDHEALTHCARE INSURANCE COMPANY, Defendants-Respondents. _______________________________

Argued April 9, 2024 – Decided April 19, 2024

Before Judges Mayer, Enright and Augostini.

On appeal from the Superior Court of New Jersey, Law Division, Bergen County, Docket No. L-8088-17.

Vafa Sarmasti argued the cause for appellant (Sarmasti PLLC, attorneys; Vafa Sarmasti, on the briefs).

Robert J. Norcia argued the cause for respondents (Stradley Ronon Stevens & Young, LLP, attorneys; Francis X. Manning, of counsel; Robert J. Norcia, on the brief).

PER CURIAM

Plaintiff BrainBuilders, LLC appeals from a September 12, 2022 order

granting summary judgment in favor of defendants Optum, Inc., Optum

Services, Inc., OptumHealth Holdings, LLC, OptumHealth Financial Services,

Inc., OptumHealthcare Solutions, LLC, OptumHealth Care Solutions, Inc.

(Optum entities), Oxford Health Insurance, Inc., Oxford Health Plans (NY),

Inc., Oxford Health Plans (NJ), Inc., Oxford Health Plans LLC (Oxford entities),

UnitedHealthcare Services, LLC, UnitedHealth Group, Inc., UnitedHealthcare

Services, Inc., UHIC Holdings, Inc., United Behavioral Health, and

A-0621-22 2 UnitedHealthcare Insurance Company (UHC entities) (collectively, defendants).

We affirm.

This matter concerns letters dated July 25, 2017 and August 2017 sent by

the Optum entities to BrainBuilders' patients following an investigation into

purported fraud by individuals associated with BrainBuilders.

BrainBuilders provides healthcare services to children on the autism

spectrum. As an out-of-network or non-participating healthcare provider,

BrainBuilders received reimbursement for claims only if a patient's health

insurance plan allowed "out-of-network benefits" or the insurer made a "single

case agreement" for the patient's care.

The Optum entities are the health claims administrator for health plans

issued or administered by the Oxford entities and UHC entities. The Optum

entities do not sell or issue health insurance policies. Rather, they provide

support for defendants who issued health insurance policies to individual

insureds.

The Optum entities also evaluate insurance claims submitted by providers

to its affiliated insurers, including BrainBuilders. The Optum entities often

investigate whether a provider has requested reimbursement beyond the

provider's entitlement, such as by misrepresenting or inflating the services

A-0621-22 3 provided. In January 2017 through approximately May 2017, the Optum entities

reviewed BrainBuilders' claims submitted for reimbursement, due to the

significant number of claims and the amounts charged in comparison to

BrainBuilders' peers.

In June 2017, four individuals related to the management of BrainBuilders

were arrested and charged with conspiracy to defraud Medicaid. A criminal

complaint, alleging misappropriation of funds, was filed against several

individuals affiliated with BrainBuilders. The arrests were reported in the news

media and the Optum entities learned of the arrests on July 14, 2017.

On July 25, 2017, the Optum entities sent letters to BrainBuilders' patients

insured by the Oxford and UHC entities (July 2017 letters). The July 2017

letters explained the Optum entities were suspending payment for services

provided by BrainBuilders "due to potential insurance fraud and other violations

of state and federal law." The letters, advising patients insured under healthcare

plans issued by the Oxford and UHC entities, stated:

Optum is responsible for making benefit coverage determinations for mental health and substance abuse services that are provided to Optum members. The availability of benefit coverage for a service is determined by the terms of your benefit plan.

This letter is to notify you that, effective [thirty] days from [insert termination date], [insert provider name]

A-0621-22 4 will no longer be reimbursed for services provided to you and/or your child/ren due to potential insurance fraud and other violations of state and federal law. Services provided by [insert provider name] after this date may not be covered under your benefit plan.

If you are in active, ongoing treatment with this practitioner, you may continue to receive services from this practitioner until [thirty] days after [insert termination date], subject to medical record review or other benefit plan requirements.

Optum is able to assist you in making arrangements for your continued treatment with a participating practitioner. Please contact us at your earliest convenience at 866-xxx-xxxx so we can assist you in locating a new provider. Our goal is to make any needed transition in your treatment as smooth as possible.

Again, if you choose to continue to see your current practitioner beyond [thirty] days after [insert termination date], you may be financially responsible for the cost of those services and have no coverage available under your benefit plan.

In August 2017, the Optum entities sent letters to BrainBuilders' patients.

(August 2017 letters). The letters stated:

Dear [name redacted]:

United Behavioral Health (UBH) is responsible for making benefit coverage determinations for mental health and substance abuse services that are provided to Oxford Health Insurance, Inc. NY-PPO members. The availability of benefit coverage for a service is determined by the terms of your benefit plan. To

A-0621-22 5 review information about your specific plan coverage, please refer to the benefit information provided by your health plan. I have reviewed your treatment plan that was submitted by Brain[B]uilders[,] LLC, and I have determined that coverage is not available under your benefit plan for the requested services of Applied Behavior Analysis.

As described in the section of your Certificate of Coverage: Based on current information available to the plan, authorization is not available due to quality of care or member safety concerns and is excluded under your plan as Non-Professional Care which is an express exclusion from coverage under your plan.

This determination does not mean that you do not require additional health care, or that you need to be discharged. Decisions about continuation of treatment should be made by you and your provider. The purpose of this letter is to inform you that coverage is not available under your benefit plan for the requested service. On 8/8/2017 1:23 PM CDT we notified your provider of this determination by telephone.

Under federal law, you have a right to request the diagnosis and diagnosis code provided to us by your provider. Alternately, you may request this information from your provider.

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