Grim v. Prudential Insurance Co. of America

859 F. Supp. 959, 1994 U.S. Dist. LEXIS 11491, 1994 WL 446027
CourtDistrict Court, D. Maryland
DecidedAugust 11, 1994
DocketCiv. A. No. PJM 93-859
StatusPublished

This text of 859 F. Supp. 959 (Grim v. Prudential Insurance Co. of America) is published on Counsel Stack Legal Research, covering District Court, D. Maryland primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Grim v. Prudential Insurance Co. of America, 859 F. Supp. 959, 1994 U.S. Dist. LEXIS 11491, 1994 WL 446027 (D. Md. 1994).

Opinion

OPINION

MESSITTE, District Judge.

I.

The Court has before it Plaintiffs Motion for Summary Judgment and Defendant’s Motion for Partial Summary Judgment.

[960]*960Plaintiff Charles Grim was an insured under a health policy written by Defendant Prudential Insurance Company of America. The core issue in this case is whether Plaintiff is entitled to coverage by Defendant’s policy with regard to (1) certain physical therapy services and (2) certain home care services received by him following a cerebral vascular accident he experienced in 1991.

Both parties contend they are entitled to summary judgment with regard to the home care services; Plaintiff also argues that he merits judgment as a matter of law with regard to the physical therapy services.

The Court concludes, with regard to the physical therapy services, that a genuine issue of material fact exists and, accordingly, Plaintiffs Motion for Summary Judgment will be denied to that extent. As to the home care services, the Court agrees that Defendant is entitled to judgment as a matter of law. Accordingly, Defendant’s Motion for Partial Summary Judgment will be granted, while Plaintiffs Motion for Summary Judgment will be denied to that extent.

II.

Plaintiff was 59 years old in November, 1991, when he suffered a cerebral vascular accident, which left him with partial paralysis on the left side, difficulty in swallowing and limitations in other life activities. At the time, he was covered under a group employee benefit policy of Defendant, which provided payments for certain services associated with illness.

On May 23, 1992, Plaintiffs primary care physician, Dr. Gary Milles, referred Plaintiff for physical therapy.

Under Part II of Defendant’s policy, coverage was provided for certain “Eligible Charges,” including “treatment by a physical or occupational therapist.” However, the policy also provided that:

A charge, or part of a charge, is not an Eligible Charge under this Part II if excluded. It is excluded to the extent it.... is described in the Generally Excluded Charges shown on a separate page.

Under the heading “Generally Excluded Charges,” the policy stated that:

[t]he following charges are not covered under either Part I or Part II of the Major Medical Expense Coverage:
(3) Charge for Unnecessary Services or Supplies: A charge for services or supplies, including test and check up exams, to the extent that they are not needed for (i) the diagnosis of a Sickness or Injury, or (ii) the medical care of a diagnosed sickness or injury.

Although Defendant had no problem authorizing the provision of physical therapy services through the end of July, 1992, it thereafter refused to extend coverage. The gist of Defendant’s refusal lay in the conclusion of its medical director that physical therapy services were not “needed for medical care,” as required by the terms of the policy. Defendant’s decision was informed at least in part by Plaintiffs age, which suggested an ability to recuperate far faster than an older patient might under similar circumstances. Plaintiffs physician, on the other hand, wrote to Defendant’s physician on September 24, 1992, stating that in his opinion Plaintiff “would benefit greatly from continued physical therapy.”

Despite this evident difference of opinion, Plaintiff asks for summary judgment on his first claim of breach of contract.1

III.

Following his vascular accident, Plaintiff also began to receive certain home care services from, among others, an entity known as [961]*961“First Call,” an individual named James Lightfoot, another named Charlotte Light-foot, and a third named Carol Halstead. In time, such services were received from entity known as “Home Care Enterprises.” The services provided by each of the individuals, as well as by Home Care Enterprises, are described by Plaintiff himself as “home care,” while the services provided by First Call are described by him as being for “personal care aid & sitter.”

Plaintiff concedes that Defendant’s policy contains an exclusion with regard to “custodial care,” which the policy further defines as:

(T)hat care that provides a level of routine maintenance for the purpose of meeting personal needs. This is care that can be provided by a lay person who does not have professional qualifications, skills or training. Custodial Care includes, but is not limited to, help in walking and getting into or out of bed; help in bathing, dressing and eating; help; other functions of daily living of a similar nature; administration of or help in using or applying medications, creams or ointments; routine administration of medical gasses after a regimen of therapy has been set up; routine care of a patient; including functions such as changes of dressings, diapers, and protective sheets and periodic turning and positioning in bed; routine care and maintenance in connection with casts, braces and other similar devices, or other equipment and supplies used in treatment of a patient, such as colostomy and ileostomy bags and indwelling catheters; routine tra-cheostomy care; general supervision of exercise programs including carrying out of maintenance programs of repetitive exercises that do not need the skills of a therapist and are not skilled rehabilitation services. (Policy, p. 58)

Plaintiff, however, contends that coverage obtains by virtue of another provision in the policy, that pertaining to “Home Health Care.” The policy defines that term thus:

A program, prescribed in writing by a person’s Doctor and administered by a Home Health Care Agency, that provides for the care and treatment of a person’s Sickness or Injury in the person’s home. (Policy, p. 59)
“Home health care agency” is defined as:
An organization that has been licensed or certified as a home health agency in the state where the home health care is given, or is a home health agency as defined in Medicare. (Policy, p. 59)

The policy specifies that “home health care services” are covered for the following:

a) Part-time or intermittent home nursing care given or supervised by a Registered Nurse (R.N.);
b) Part-time or intermittent home health aide service, mainly for care of the person;
c) Nutritional counseling furnished or supervised by a registered dietician. (Policy, p. 20)

Significantly, however, the policy provides that the foregoing services are included, “only if all of these conditions are met”:

a) The services are not mainly Custodial Care;
b) The services are prescribed in writing by the person’s Doctor
1) as medically needed for the care and treatment of the person’s Sickness or Injury in the person’s home; and
2) as being in place of the person’s inpatient stay in a Hospital or Convalescent Nursing Home that would be required in the absence of such services; and
3) no later than 14 days after the start of the home health care.

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Cite This Page — Counsel Stack

Bluebook (online)
859 F. Supp. 959, 1994 U.S. Dist. LEXIS 11491, 1994 WL 446027, Counsel Stack Legal Research, https://law.counselstack.com/opinion/grim-v-prudential-insurance-co-of-america-mdd-1994.