Brainbuilders, LLC v. Oscar Garden State Insurance Corporation

CourtNew Jersey Superior Court Appellate Division
DecidedDecember 11, 2025
DocketA-3514-23
StatusUnpublished

This text of Brainbuilders, LLC v. Oscar Garden State Insurance Corporation (Brainbuilders, LLC v. Oscar Garden State Insurance Corporation) 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. Oscar Garden State Insurance Corporation, (N.J. Ct. App. 2025).

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NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ."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-3514-23

BRAINBUILDERS, LLC,

Plaintiff-Appellant,

v.

OSCAR GARDEN STATE INSURANCE CORPORATION,

Defendant-Respondent. ___________________________

Argued November 12, 2025 – Decided December 11, 2025

Before Judges Susswein, Chase and Augostini.

On appeal from the Superior Court of New Jersey, Law Division, Ocean County, Docket No. L-1714-19.

Peter M. Slocum argued the cause for appellant (Lowenstein Sandler, LLP, and Sarmasti PLLC, attorneys; Peter M. Slocum, Anish Patel and Vafa Sarmasti, of counsel and on the briefs).

David Jay argued the cause for respondent (Greenberg Traurig, LLP, attorneys; David Jay, Todd L. Schleifstein and Samantha L. Varsalona, on the brief).

PER CURIAM This appeal concerns a dispute between a service provider and a health

insurance carrier. Plaintiff BrainBuilders, LLC (BrainBuilders) provided

behavioral health services to eight children with autism. Defendant Oscar

Garden State Insurance Corporation (Oscar) provided health insurance coverage

for the children but did not include BrainBuilders as an in-network provider.

The children's insurance plans do not reimburse out-of-network providers unless

there is a case-specific approval for services, known as a Single Case Agreement

(SCA).

BrainBuilders appeals from a May 6, 2024 Law Division order granting

summary judgment in Oscar's favor, dismissing plaintiff's claims of breach of

implied contract, promissory estoppel, unjust enrichment, and quantum meruit.

BrainBuilders also appeals from the trial court's order denying its motion for

reconsideration. After reviewing the record in light of the governing legal

principles, we affirm.

I.

We discern the following pertinent facts and procedural history from the

record. BrainBuilders provided services, including applied behavioral analysis

(ABA), to eight minor patients: R.G., L.K., Y.F., E.G., S.S., Y.S., S.T., and

A-3514-23 2 Y.T.1 All except Y.F. were already in BrainBuilders' care when they became

insured by Oscar. Under the Oscar health insurance plans, seven patients had

no coverage at all for services by out-of-network providers. The eighth patient,

Y.T., had a plan that included fifty percent co-insurance for out-of-network

behavioral health services. Oscar denied reimbursement to BrainBuilders for

services provided to the eight patients without an SCA.

BrainBuilders' Director of Finances, Simon Nussbaum, testified that the

"most common situation" in which the parties would execute an SCA was to

maintain "continuation of care" despite a change in a child's insurance coverage.

According to Oscar and its administrator, Optum, the purpose of these

agreements was to permit necessary care while giving a patient time to

"transition to in-network providers."

The parties entered at least one SCA for each of the eight patients' care.

Each SCA was limited to specific treatments for a specific patient.

A representative SCA stated in pertinent part: "It is understood that this

SCA is ONLY for the Member listed above and the Service(s) listed above. It

is not a general participation agreement and Provider is not considered an in -

1 We use initials to protect the confidentiality of the children's medical records. See R. 1:38-3(a)(2). A-3514-23 3 network provider with Oscar." It further stated: "To the extent that additional

services beyond those set forth above are needed, additional authorization must

be sought by Provider prior to the services being provided or Provider will be

responsible for the full cost of the additional services." It also provided that

certain "medically necessary service(s) beyond those set forth" in the SCA

would "be reimbursed at the discretion of Oscar at no more than the lesser of

billed charges, Oscar's prevailing reimbursement rate, or 100% of the Medicare

Fee Schedule."

BrainBuilders or its patients sought SCAs for ABA therapy. Optum

responded to many applications for SCAs for ABA therapy with a denial letter

including the names of in-network providers.

Nussbaum was not satisfied with the case-by-case SCA process and

attempted to negotiate an overall agreement in which Oscar would reimburse

claims for BrainBuilders' ABA services. Initially, Nussbaum offered Oscar an

"overall" rate agreement that would cover any out-of-network behavioral health

services BrainBuilders provided to Oscar's insureds. Nussbaum later proposed

a different rate agreement to Optum, based on an agreement he had reached with

another health insurer. Optum responded that it was reviewing the offer and

A-3514-23 4 "working with Oscar to seek their approval since it is their money that [was]

paying for all of this."

Nussbaum reprised his offer to Oscar to establish an "umbrella" agreement

"for all services that Brain[B]uilders provides to children with autism." Oscar

representative Yael Kino responded:

I've forwarded your message to the relevant stakeholders for review. In the meantime, can you confirm whether or not you have been able to finalize the contracts with Optum for the ABA therapy?

We want to make sure [BrainBuilders] is getting reimbursed for services that are currently taking place.

Nussbaum replied:

Optum has yet to work out the final details in regard to the SCA for ABA therapy and they are giving us a very hard time. Furthermore in regard to one [patient, L.K.,] they left us a message they will be terminating the agreement going forward as per the plan (even though there is really no one the child can transition to).

In further emails to Kino, Nussbaum continued to request a rate agreement

for services rendered to Oscar's insureds and reiterated that BrainBuilders had

not reached an agreement with Optum. He complained about E.G. in particular,

who he believed—like L.K.—had "nowhere to transfer . . . to [without being]

damaged by the transfer, and maybe nowhere at all to transfer her to."

A-3514-23 5 BrainBuilders continued to press Oscar to accept its proposal, but

according to Nussbaum, the parties "never came to a one size fits all rate

agreement." Nussbaum testified his negotiations with Kino came to "a harsh

end." Similarly, he testified his negotiations with Optum "slipped by the

wayside" as no "actual rates agreement" was ever reached. In the meantime,

BrainBuilders continued to provide ABA services to the eight patients even after

the parties' negotiations stalled.

BrainBuilders billed Oscar a total of $8,265,820 for services rendered to

the eight patients. Oscar paid $842,964 in reimbursements in accordance with

the SCAs. Nussbaum complained to Oscar about the reimbursements. He told

Oscar he believed it had "approved the authorization" for all these patients' ABA

services, but that Optum failed "to finalize the rates." Oscar replied that the

SCAs provided that "if any additional services not outlined in the SCA need to

be rendered, the provider will obtain prior authorization prior to rendering those

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