In re Estate of Seiler

2021 Ohio 115
CourtOhio Court of Appeals
DecidedJanuary 20, 2021
Docket29756
StatusPublished

This text of 2021 Ohio 115 (In re Estate of Seiler) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re Estate of Seiler, 2021 Ohio 115 (Ohio Ct. App. 2021).

Opinion

[Cite as In re Estate of Seiler, 2021-Ohio-115.]

STATE OF OHIO ) IN THE COURT OF APPEALS )ss: NINTH JUDICIAL DISTRICT COUNTY OF SUMMIT )

IN THE MATTER OF THE ESTATE OF C.A. No. 29756 BRENAN JOSEPH SEILER

APPEAL FROM JUDGMENT ENTERED IN THE COURT OF COMMON PLEAS COUNTY OF SUMMIT, OHIO CASE No. 2019 ES 476

DECISION AND JOURNAL ENTRY

Dated: January 20, 2021

SCHAFER, Judge.

{¶1} Western Reserve Hospital, LLC and Western Reserve Hospital’s Employee

Medical Benefit Plan (collectively “Western Reserve”), appeal the decision of the Summit County

Court of Common Pleas, Probate Division. For the reasons that follow, this Court reverses.

I.

{¶2} This appeal arises from an unpaid medical bill that has spawned litigation in both

state and federal court. Appellant, Western Reserve, denied coverage for services provided to

decedent, Brenan Seiler, during his last illness. Appellee, Summa Health Systems, Inc.

(“Summa”), then opened the Estate of Brenan Seiler (“the Estate”) and, after being appointed

administrator of the Estate, Summa presented its own creditor claim for the medical bill as a

contingent claim against the Estate. Summa, in its individual capacity and as administrator of the

Estate, filed a complaint in the United States District Court asserting Employee Retirement Income

Security Act (“ERISA”) claims against Western Reserve. The commencement of the federal suit 2

prompted Western Reserve to intervene in the probate proceedings to object to Summa’s creditor

claim.

{¶3} The facts underlying the appeal began on May 12, 2018, when Mr. Seiler presented

to Summa’s emergency room for treatment due to an accidental drug and alcohol overdose. Mr.

Seiler remained hospitalized and received care from Summa until he died as a result of his

condition several days later, on May 18, 2018.

{¶4} Mr. Seiler was an insured, or covered individual, under a health benefit plan

through Western Reserve (the “Plan”). As a covered individual, Mr. Seiler was eligible to receive

health care benefits for covered services under the Plan. “Covered services” are defined as

medically necessary health services as determined by the Plan. Summa is party to a “facility

agreement” with the Plan. This facility agreement defines and governs certain aspects of Summa’s

rights and responsibilities regarding claims for payment of covered services for individuals

covered by, or insured through, the Plan.

{¶5} “On or about September 12, 2018,” Summa submitted a request for “payment in

the amount of $341,339.50 from the Plan for the treatment Summa had provided” to Mr. Seiler

between May 12-18, 2018. On October 15, 2018, Western Reserve issued an “Adverse

Determination Notice” to Summa, denying Summa’s claim for payment. According to Summa,1

the adverse determination notice stated as the basis for its denial that Mr. Seiler’s emergency

department visit and hospitalization were the result of illegal activity, to wit: Mr. Seiler’s substance

abuse, which included illicit drug use and significantly contributed to his cardiac arrest.

1 Neither the adverse determination letter, nor the actual language of that letter appears in the record. 3

{¶6} Summa asserted that the adverse determination notice informed Summa of its “right

to a second-level appeal and invited Summa to perfect such an appeal * * *.” Summa also cited

to the facility agreement as the source of an appeals process Summa was required to follow.

Regarding appeals and adjustment requests, the facility agreement states:

If [Summa] believes a Claim has been improperly adjudicated for a Covered Service, for which [Summa] timely submitted a Claim to Plan, [Summa] must submit a written request for an appeal or adjustment with Plan within two (2) years from the date of Plan’s payment or explanation of payment. The request must be submitted in accordance with Plan’s payment appeal process. Request for appeals or adjustments submitted after this date may be denied for payment, and [Summa] will not be permitted to bill [the Plan] or the Covered Individual for those services for which payment was denied.

The facility agreement does not include an explanation or description of the Plan’s payment appeal

process.

{¶7} Summa submitted verbal and written appeals of the adverse determination to

Western Reserve on or about December 14, 2018, February 4, 2019, and March 14, 2019. In the

federal complaint, Summa asserted that the “Plan provides that post-service appeals must receive

a written determination within 30 calendar days after receipt of the appeal request.” However,

Summa alleged, the Plan “did not respond to Summa’s verbal and written second-level appeal

requests.”

{¶8} On April 15, 2019, Summa sent a letter to Western Reserve requesting federal

external review, asserting Western Reserve failed to engage in the claims appeal process. The

Plan’s appeals coordinator issued a letter on April 22, 2019, responding to Summa’s request for

an external review. The Plan denied Summa’s request, stating that the denial of the claim was

ineligible for external review both under the Plan and under the law. The letter also stated Summa

was “not entitled to use the external review appeal process to adjudicate its claim for payment

because it [was] not a covered person or the authorized representative of Plan participant.” 4

{¶9} Summa mailed a statement addressed to Mr. Seiler on May 16, 2019, requesting

payment in the amount of $341,339.50. On May 23, 2019, Summa opened the Estate as a creditor

of the Estate. The probate court granted Summa’s application and appointed Summa administrator

of the Estate.

{¶10} Summa presented its creditor claim against the Estate on June 14, 2019. Summa

alleged that the Estate is indebted in the amount of $341,339.50 for medical services provided to

Mr. Seiler, which had recently become his financial obligation. Summa acknowledged the six-

month window that generally applies to creditor claims but asserted that its claim did not accrue

until the end of its appeals process on April 23, 2019. Summa moved the probate court—and itself

as the administrator—to allow its claim as a timely contingent claim.

{¶11} Summa filed the federal complaint asserting ERISA claims against Western

Reserve on June 27, 2019. Meanwhile, Western Reserve appeared and filed an objection to

Summa’s creditor claim in the probate court. Western Reserve challenged Summa’s contention

that the claim was contingent and argued, inter alia, the claim was time-barred and Summa was

not a creditor of the Estate. The federal district court stayed the matter pending the probate court’s

ruling on the objection to Summa’s creditor claim because the ruling would be central to the issue

in the federal case: “whether Summa may bring an ERISA claim in [federal court] as Administrator

of the Estate.”

{¶12} Summa and Western Reserve briefed the issues for the probate court and submitted

the matter to a magistrate for decision. The magistrate found that Summa’s claim did not accrue

until the Plan made its final decision that it would not cover the cost of services Summa provided

to Mr. Seiler. The magistrate concluded that Summa’s claim was “merely contingent” and not

“ripe for presentment” to the Estate until Western Reserve’s ultimate denial of payment. The 5

magistrate interpreted the Plan’s April 23, 20192 letter informing Summa it was ineligible for

Free access — add to your briefcase to read the full text and ask questions with AI

Related

In re Estate of Greer
2011 Ohio 6721 (Ohio Court of Appeals, 2011)
In re Piesciuk
2012 Ohio 2481 (Ohio Court of Appeals, 2012)
Keifer, Exr. v. Kissell, Admx.
75 N.E.2d 692 (Ohio Court of Appeals, 1947)
Fields v. Cloyd, 24150 (10-8-2008)
2008 Ohio 5232 (Ohio Court of Appeals, 2008)
Pierce v. Johnson, Exr.
23 N.E.2d 993 (Ohio Supreme Court, 1939)
Embassy Healthcare v. Bell (Slip Opinion)
2018 Ohio 4912 (Ohio Supreme Court, 2018)

Cite This Page — Counsel Stack

Bluebook (online)
2021 Ohio 115, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-estate-of-seiler-ohioctapp-2021.