Mennealy v. Healthsource Maine, Inc.

CourtSuperior Court of Maine
DecidedApril 28, 2000
DocketCUMcv-99-228
StatusUnpublished

This text of Mennealy v. Healthsource Maine, Inc. (Mennealy v. Healthsource Maine, Inc.) is published on Counsel Stack Legal Research, covering Superior Court of Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Mennealy v. Healthsource Maine, Inc., (Me. Super. Ct. 2000).

Opinion

STATE OF MAINE BO SUPERIOR COURT

CUMBERLAND, ss. ee CIVIL ACTION oe BEDI DOCKET NO. CV;99:228 ROBERT MENNEALY ahd |) 5 23 8 REC CUM p92 3 PATRICIA MENNEALY, a a Plaintiffs v. ORDER

HEALTHSOURCE MAINE, INC.

Defendant

This matter is before the Court on Plaintiffs Robert and Patricia Mennealy’s motion to lift a stay imposed by this Court on April 28, 2000. Also before the Court is Defendant Healthsource’s motion for declaratory relief and motion to amend or supplement its answer.

FACTUAL BACKGROUND

In early November, 1998, Robert Mennealy suffered a severe stroke and was admitted to Central Maine Medical Center (“CMMC”). At that time, Mr. Mennealy received health care insurance under a Group Subscriber Agreement from Healthsource as a dependent spouse of Patricia Mennealy through her employer, the State of Maine.

During his stay at CMMC, Mr. Mennealy’s request for admission to River Ridge Center for Rehabilitation’s Brain Injury program (“River Ridge”) was denied by the Defendant. Admission to Marshwood nursing home was instead authorized by the Defendant. On January 8, 1999, Mr. Mennealy’s stay at the Marshwood facility

was terminated by the Defendant. Shortly after Mr. Mennealy’s discharge from Marshwood, a box of safety equipment was delivered to the Plaintiffs’ residence. Some of the equipment was backordered and did not arrive until some time later. A delay in installation of the equipment that was delivered occurred because Healthsource did not notify the Plaintiffs that they were responsible for the installation.

Also after his discharge from Marshwood, Mr. Mennealy’s primary care physician requested authorization for payment for Automove 800 therapy (“AM800 therapy”). This authorization was denied by the Defendant. On August 2, 1999, the proposed provider of the ‘M800 therapy sought appeal on Mr. Mennealy’s behalf. Defendant’s Opposing Memorandum Tab (“Tab”) U. After the Defendant denied the initial appeal, the proposed provider requested second level grievance review. Tabs V & W. Following a full grievance hearing, Healthsource granted the grievance on December 15, 1999 and authorized benefits for a 3-month trial of AM800 therapy. Tab X.

On February 4, 1999, the Defendant denied authorization for a neuropsychology examination that was scheduled for February 5, 1999, claiming the examination was not medically necessary. Tab O. On February 22, 1999, Healthsource authorized 8 hours of neuropsychology testing. Id. The Defendant issued Ms. Mennealy an apology on that date and gave her an authorization number. Id. Ms. Mennealy’s letter requesting an appeal to review the denial of this benefit was received by Healthsource on February 25, 1999. Id. The appeal was

withdrawn on March 9, 1999 and the neuropsychology testing occurred on March 17, 1999. Id.

Healthsource terminated Mr. Mennealy’s outpatient physical and occupational therapy services from Central Maine Rehabilitation Services (“CMRS”) effective March 11,1999. In August, 1999, Mr. Mennealy was accepted into the outpatient brain injury program at Westside Neurorehabilitation Services (“Westside”). Although his primary care physician requested authorization for Westside’s services, the Defendant denied the request.

The Plaintiffs’ seven-count second amended complaint alleges that the Defendant wrongfully (2) denied benefits for the River Ridge program; (2) terminated Mr. Mennealy’s stay at the Marshwood nursing home; (3) delayed installatior’ of necessary equipment in the Mennealy home; (4) denied authorization for the February 5, 1999 neuropsychology examination; (5) terminated physical and occupational therapy at CMRS; (6) denied benefits for the Westside program; and (7) denied authorization for payment for AM800 therapy.

On April 28, 2000, Counts II-IV of the second amended complaint were dismissed without prejudice. Also-on that date, this Court denied the Defendant's motion for summary judgment and stayed the remaining breach of contract, Unfair Claims Settlement Practices Act (“UCSPA”) and emotional distress claims until the Plaintiffs exhausted their administrative remedies on the breach of contract and UCSPA claims.

On May 31, 2000, the Plaintiffs filed an “Appeal and Complaint” to the State

Employee Health Commission (“SEHC”) Appeals Panel. Tab A. The SEHC dismissed the appeal on August 29, 2000, concluding the Plaintiffs had not exhausted the administrative remedies available under the Group Subscriber Agreement. Tab B. The Plaintiffs then requested first level appeal on August 30, 2000 of the River Ridge and Marshwood denials, the delay in obtaining medical equipment and the Defendant’s failure to provide adequate case management services.! Tab C.

The Defendant addressed the issues raised in the first level appeal by written decision dated October 4, 2000. That decision concluded that any delay in obtaining medical equipment was a ‘wuality, not a benefit, issue. Tab T. It also reflects that both the River Ridge and Marshwood denials were submitted for independent review to Dr. Michael Cheikin, who concluded that both denials were improper. Tabs D & T. Dr. Cheikin determined that further inpatient stay at Marshwood was no longer appropriate but was not able to determine whether inpatient treatment at River Ridge was still appropriate. Tabs D & T. Although Healthsource submitted additional information to Dr. Cheikin regarding treatment at River Ridge, he was unable to determine whether inpatient care remained appropriate. Tabs B & F. The Defendant therefore denied that aspect of the appeal on October 30, 2000. Tab G. The Plaintiffs filed a grievance level appeal of the River Ridge denial on February 8, 2001. Tab H. That appeal was subsequently withdrawn on March 9, 2001 because the

Plaintiff was not interested in obtaining inpatient treatment at that time. Tab M.

1 This denial was raised by the Plaintiffs for the first time in their Opposition to Defendant's Motion for Summary Judgment dated January 13, 2000 and was not pled by the Plaintiffs in their second amended complaint. On August 30, 2000, the Plaintiffs requested second level grievance review of Healthsource’s denial of authorization and payment for therapy at CMRS and Westside. Tab N. The Management Grievance Committee upheld the original decisions to deny therapy at CMRS and services at Westside but approved individual neuropsychologic counseling at Westside on October 23, 2000. Tab O. On appeal, the State of Maine Bureau of Insurance referred the matter to the Center for Health Dispute Resolution (“CHDR”)-for external review. Tab P. The CHDR issued its decision on January 16, 2001, reversing the Defendant’s denial of the benefits for the remaining services in ‘dispute at CMRS and Westside and ordered payment of those services. Tab P. The decision did not address the Plaintiffs’ request for external review of their request for services that were never received. See Tabs P, Q,

R&S.

DISCUSSION I. Plaintiffs’ Motion to Lift Stay The doctrine of exhaustion of administrative remedies requires the Plaintiffs to pursue all possible administrative remedies before initiating an action in the

Superior Court. See Baker v. Klein, 655 A.2d 367, 368-69 (Me. 1995); Cushing _v.

Smith, 457 A.2d 816, 821 (Me. 1983). The Group Subscriber Agreement provides for two levels of internal review: first-level appeal and second-level grievance review. Group Subscriber Agreement (“Agreement”) § 12(B) & (C). The SEHC represents the

final level of appeal. Id. § 12(E); 5 M.R.S.A. § 286 (1989 & Pamph. 2000). Insureds may also contact the Maine Bureau of Insurance to seek aid in resolving an appeal. Agreement § 12(F).

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Related

Baker v. Klein
655 A.2d 367 (Supreme Judicial Court of Maine, 1995)
Cushing v. Smith
457 A.2d 816 (Supreme Judicial Court of Maine, 1983)

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