Hamsher v. North Cypress Medical Center Operating Co.

620 F. App'x 236
CourtCourt of Appeals for the Fifth Circuit
DecidedJuly 29, 2015
Docket14-20576
StatusUnpublished

This text of 620 F. App'x 236 (Hamsher v. North Cypress Medical Center Operating Co.) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fifth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hamsher v. North Cypress Medical Center Operating Co., 620 F. App'x 236 (5th Cir. 2015).

Opinion

PER CURIAM: *

In this ERISA case, we must decide whether the plaintiffs medical expenses were incurred at a “hospital.” Concluding that the administrative record does not support the insurer’s determination that they were, we reverse.

I.

A.

North Cypress Medical Center provides health insurance to its employees through its self-funded Employee Benefit Plan (the “Plan”). As with many insurers, North Cypress must pre-approve certain medical treatments. If pre-approval is required, but not received, North Cypress may reduce its payment to its beneficiaries, or deny reimbursement altogether.

The Plan has two types of pre-approval. The first is called “precertification,” and it applies to all “hospitalizations” and “inpatient mental disorder/substance use disorder treatments.” 1 To precertify, the covered person or a~ family member must contact North Cypress’s medical management subcontractor, Meritain Health Medical Management, at least 48 hours before treatment is to begin. 2 Meritain will then determine how many days of treatment aré medically necessary. That said, a failure to precertify is not an absolute bar to reimbursement. “If a Covered Person does not obtain precertification, as required for certain benefits under the Plan, eligible expenses will be reduced by $500.”

The second type of pre-approval is more stringent, and is called “prior-authorization” (although it is sometimes referred to in the briefing as “pre-authorization”). Prior-authorization is an absolute precondition to reimbursement; North Cypress will not pay for certain services unless the “service or specialty is not available at [North Cypress] and prior authorization has been obtained from [North Cypress] Human Resources Department.” As is *238 relevant here, both inpatient and outpatient hospital services must be prior-authorized. And the Plan defines “[h]ospi-tal” to include “[a] facility operating legally as a psychiatric [h]ospital or residential treatment facility for mental health and licensed as such by the state in which the facility operates.” 3

B.

Rebecca Hamsher was employed by North Cypress as a nurse and was insured through its Plan. In May 2011, she was admitted to Timberline Knolls Residential Treatment Center (“Timberline”) in Illinois, where she was diagnosed with various mental disorders. She was treated at Timberline through December 2011, although the administrative record is not clear as to the nature of her treatment. What is clear, however, is that North Cypress did not precertify or prior-authorize her medical treatment.

North Cypress refused to pay. 4 Hamsher internally appealed in January 2012, and North Cypress again denied her claim. It concluded that “based on evidence in the administrative record showing that [she] failed to obtain the necessary prior authorization,” she “was not eligible to receive benefits.” 5

Unsatisfied, Hamsher filed suit against North Cypress in federal district court, seeking “to recover benefits due to [her] under the terms of [her] plan,” as provided by the Employee Retirement Income Security Act (“ERISA”). 6 North Cypress moved for summary judgment. Shortly after, Hamsher moved to supplement the administrative record, which the district court denied. The court also granted North Cypress’s summary judgment motion. In a brief order, it concluded that Hamsher was required to get prior-authorization for her treatment at Timberline, *239 and since she conceded she had failed to do so, North Cypress was entitled to deny her claim.

This timely appeal of the district court’s orders granting summary judgment and denying Hamsher’s motion to supplement the administrative record follows.

II.

“Standard summary judgment rules control in ERISA cases.” 7 We review the district court’s grant of summary judgment de novo, applying the same standards as the district court. 8 “The court shall grant summary judgment if the mov-ant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.” 9

We review “an administrator’s factual determinations in the course of a benefits review,” as at issue here, for abuse of discretion. 10 - This standard is far from demanding.

Abuse of discretion review is synonymous with arbitrary and capricious review in the ERISA context. - When reviewing for arbitrary and capricious actions resulting in an abuse of discretion, we affirm an administrator’s decision if it is supported by substantial evidence. Substantial evidence is more than a scintilla, less than a preponderance, and is such relevant evidence as a reasonable mind might accept as adequate to support a conclusion. A decision is arbitrary only if made without a rational connection between the known facts and the decision or between the found facts and the evidence. 11

“A plan administrator abuses its discretion where the decision is not ‘based on evidence, even if disputable, that clearly supports the basis for its denial.’ ” 12

North Cypress denied Hamsher’s claim because it concluded that she had neither asked for nor received prior-authorization for “hospital expenses incurred at hospitals other than North Cypress.” Under the terms of the Plan, North Cypress’s denial was proper if Hamsher’s expenses were incurred at a hospital, a category which explicitly includes a “residential treatment facility for mental health and licensed as such by the state in which the facility operates.” If, however, Hamsher received “mental health ... treatment” at a non-hospital facility, prior-authorization was not required, and she is entitled to at least partial reimbursement. 13

*240 The problem is that the administrative record is essentially silent as to the nature of Hamsher’s treatment. We know that she was treated for various mental disorders at a facility called “Timberline Knolls Residential Treatment Center,” but the record says nothing about whether this facility is a “residential treatment facility for mental health and licensed as such by the state [of Illinois].” Rather, the administrative file contains only claim forms, none of which provide an indication as to whether Timberline is a “hospital” as defined under the Plan. The name is sugges-' five, of course, but title alone does not constitute the type of “substantial evidence” that North Cypress must put forward.

This conclusion accords with our precedent.

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Bluebook (online)
620 F. App'x 236, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hamsher-v-north-cypress-medical-center-operating-co-ca5-2015.