Inter Valley Health Plan v. Blue Cross/Blue Shield of Connecticut

16 Cal. App. 4th 60, 19 Cal. Rptr. 2d 782, 93 Daily Journal DAR 6626, 93 Cal. Daily Op. Serv. 3961, 1993 Cal. App. LEXIS 569
CourtCalifornia Court of Appeal
DecidedMay 27, 1993
DocketG012384
StatusPublished
Cited by4 cases

This text of 16 Cal. App. 4th 60 (Inter Valley Health Plan v. Blue Cross/Blue Shield of Connecticut) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Inter Valley Health Plan v. Blue Cross/Blue Shield of Connecticut, 16 Cal. App. 4th 60, 19 Cal. Rptr. 2d 782, 93 Daily Journal DAR 6626, 93 Cal. Daily Op. Serv. 3961, 1993 Cal. App. LEXIS 569 (Cal. Ct. App. 1993).

Opinion

Opinion

SILLS, P. J.

The cost of Anjanette Farace’s bone marrow transplant and chemotherapy exceeded half a million dollars. Fortunately, she was covered by the health plans provided by each of her divorced parents’ respective employers.

In fact, both plans—to their credit—paid for the treatment, leaving Children’s Hospital of Orange County overpaid by some $511,000. The hospital deposited this money into the registry of the Orange County Superior Court, and the mother’s plan, Inter Valley Health Plan, sued the father’s plan, an employee medical plan administered by Blue Cross/Blue Shield of Connecticut (Blue Cross), to determine which plan was primarily responsible.

After a trial on stipulated facts and declarations submitted with the trial briefs, the court determined that the matter was governed by the federal *63 employee benefits law known as ERISA, 1 and, under ERISA, as interpreted by PM Group Life Ins. v. Western Growers Assur. Trust (9th Cir. 1992) 953 F.2d 543 (PM Group Life), the mother’s plan was primary because her birthday comes earlier in the calendar year than the father’s birthday (the birthday rule).

We reverse. PM Group Life did not involve divorced parents, and the distinction between a married couple and a divorced one is important in this context: a married couple is ordinarily one economic unit, a divorced couple is two. While we conclude this case is governed by ERISA, we also conclude that because ERISA does not have a coordination of benefits provision the appropriate rule under ERISA is to defer to the law of the forum state—here, California. And, under California law as it applies to divorced parents in the light of Anjanette’s parents’ divorce decree, it is her father’s plan that is primarily responsible for her health care expenses.

I

We first tackle the question of whether this case is governed directly by ERISA or by state law. The preemption language in ERISA has been well explored in a series of federal decisions (e.g., FMC Corp. v. Holliday (1990) 498 U.S. 52 [112 L.Ed.2d 356, 111 S.Ct. 403]; Metropolitan Life Ins. Co. v. Mass. (1985) 471 U.S. 724 [85 L.Ed.2d 728, 105 S.Ct. 2380]). The language is structured in three parts. First there is a broad preemption clause, preempting state laws which “relate to any employee benefit plan.” 2 Then there is a “saving clause” which excludes any state law which “regulates insurance” from the scope of the preemption clause. 3 Finally, there is a “deemer” clause which, as a practical matter, carves out an exception to the saving clause by *64 providing that employee benefit plans shall not be “deemed” insurance companies for purposes of the saving clause. 4

Accordingly, preemption under ERISA is tested under a three-step analysis: First, does the state law relate to an employee benefit plan? Second, does the state law regulate insurance? Third, may the plan be deemed an insurer under the state law? (See Moore v. Provident Life & Acc. Ins. Co. (9th Cir. 1986) 786 F.2d 922, 926.)

The California coordination of benefits regulations undoubtedly both “relate to” the employee benefit plans in this case and “regulate insurance.” (See Shaw v. Delta Air Lines Inc. (1983) 463 U.S. 85, 96-97 [77 L.Ed.2d 490, 500-501, 103 S.Ct. 2890] [giving broad meaning to “relate to”]; PM Group Life, supra, 953 F.2d at p. 546 [“Our only remaining question is whether California’s coordination of benefits provision is a state insurance regulation. No doubt it is.”].) The key issue is whether the father’s plan is deemed an “insurance company.”

For better or worse, the test laid down by the United States Supreme Court on the application of the deemer clause is whether the particular plan in question is self-funded. (FMC Corp., supra, 498 U.S. at pp. 58-63 [112 L.Ed.2d at pp. 365-367, 111 S.Ct at p. 409].) If so, the plan is governed by ERISA. On the other hand—and here is where it gets a little tricky— “employee benefit plans that are insured are subject to indirect state insurance regulation.” (Ibid.) By “indirect regulation,” the Supreme Court reveals that a state may regulate any insurer that issues a policy purchased by a plan: “Our interpretation of the deemer clause makes clear that if a plan is insured, a State may regulate it indirectly through regulation of its insurer and its insurer’s insurance contracts; if the plan is uninsured, the State may not regulate it.” (498 U.S. at pp. 63-66 [112 L.Ed.2d at pp. 368-369, 111 *65 S.Ct at p. 411].) 5 The Supreme Court did not go so far as to say that a state may directly regulate any plan that buys insurance for itself.

In the instant case, the father’s plan is self-funded, but purchases aggregate stop-loss insurance. 6 The parties have stipulated that under the stop-loss arrangement the insurer reimburses the father’s plan “for the amount by which total paid claims for all participants in the plan exceed certain specified limits.”

The Ninth Circuit has already dealt with the question of whether ERISA governs employee benefit plans which, while self-funded, purchase stop-loss insurance policies. It does. (United Food & Commercial Workers v. Pacyga (9th Cir. 1986) 801 F.2d 1157, 1161-1162; Moore v. Provident Life & Acc. Ins. Co., supra, 786 F.2d at pp. 926-927.) While Inter Valley cites us contrary authority from the Sixth Circuit (Northern Group Services v. Auto Owners Ins. Co. (6th Cir. 1987) 833 F.2d 85, 91; Michigan United Food and Commercial v. Baerwaldt (6th Cir. 1985) 767 F.2d 308, 312-313), we believe Pacyga and Moore to be the better reasoned cases.

The Supreme Court did not set up a simple self-funded-equals-preempted, insured-equals-nonpreempted dichotomy.

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Bluebook (online)
16 Cal. App. 4th 60, 19 Cal. Rptr. 2d 782, 93 Daily Journal DAR 6626, 93 Cal. Daily Op. Serv. 3961, 1993 Cal. App. LEXIS 569, Counsel Stack Legal Research, https://law.counselstack.com/opinion/inter-valley-health-plan-v-blue-crossblue-shield-of-connecticut-calctapp-1993.