Midkiff v. The Anthem Companies, Inc.

CourtDistrict Court, E.D. Virginia
DecidedApril 2, 2025
Docket3:22-cv-00417
StatusUnknown

This text of Midkiff v. The Anthem Companies, Inc. (Midkiff v. The Anthem Companies, Inc.) is published on Counsel Stack Legal Research, covering District Court, E.D. Virginia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Midkiff v. The Anthem Companies, Inc., (E.D. Va. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division WINIFRED MIDKIFF, et al., on behalf +) of themselves and all others similarly ) situated, ) ) Plaintiffs, ) ) v. ) Civil Action No, 3:22-cv-417-HEH ) □ THE ANTHEM COMPANIES, INC., ) et al., ) ) Defendants. ) MEMORANDUM OPINION (Resolving Summary Judgment Motions and Motion to Decertify) THIS MATTER is before the Court on a Motion to Decertify the Conditionally Certified Collective (“Motion to Decertify,” ECF No. 105) and a Motion for Summary Judgment (ECF No. 107), both filed on November 30, 2023, by Defendants The Anthem Companies, Inc., Anthem Health Plans of Virginia, Inc. d/b/a Anthem Blue Cross and Blue Shield, and Amerigroup Corporation (collectively, “Defendants” or “Anthem”. Also before the Court is a Motion for Partial Summary Judgment (ECF No. 97) filed on November 30, 2023, by Plaintiffs Winifred Midkiff (“Midkiff”) and Ardaith Brown, on behalf of themselves and all others similarly situated (collectively, “Plaintiffs”). Defendants’ Motion to Decertify (ECF No. 105) seeks to decertify the conditionally certified Fair Labor Standards Act (“FLSA” or the “Act”) collective, arguing that the Plaintiffs are not “similarly situated” because they had different clinical

specialties, they worked on different teams, and they applied different guidelines when processing insurance claims. The cross motions for summary judgment and partial summary judgment each seek a ruling from this Court on whether the Plaintiffs are exempt from the overtime protections in the FLSA and the Virginia Overtime Wage Act (“VOWA”) under the learned professional and administrative exemptions, as well as the good faith defense. (ECF Nos. 98, 108). The parties’ primary disagreement is whether Plaintiffs’ employment duties required the exercise of judgment and discretion. For the reasons that follow, the Court will deny Defendants’ Motion to Decertify and Motion for Summary Judgment and the Court will grant in part and deny in part Plaintiffs’ Motion for Partial Summary Judgment. I. BACKGROUND A. Factual Background Plaintiffs are Registered Nurses (“RNs”) who work or worked for Anthem in Virginia as utilization reviewers in one of three positions: Nurse Medical Management (“NMM”) I, NMM II, and NMM Senior, (Second Am. Compl. { 4, 74; ECF No. 109 439.) The primary responsibility of NMMs was “to perform utilization reviews, also called ‘medical necessity’ reviews, of authorization requests submitted by healthcare providers.” (ECF No. 102 at 5.) These utilization reviews required the NMMs to evaluate the authorization requests, determine whether they met certain criteria, and then

approve coverage or recommend denial of coverage. (Approval — Initial Inpatient Review Quick Reference Guide at 3, ECF No. 102-26; ECF No. 102 at 4-7.)

The NMMs followed a step-by-step process to determine whether the criteria were

met, and, if they were, the NMMs could approve the authorization request. (Mar. 18, 2024 Tr. at 91-99, ECF No. 179; see generally Approval — Initial Inpatient Review Quick Reference Guide.) If the criteria were not met, the NMMs were required to send the request to a Medical Director (a medical provider such as a physician) for a final determination. (Approval — Initial Inpatient Review Quick Reference Guide at 3; Mar. 18, 2024 Tr. at 91-99.) The NMMs were not permitted to deny any authorization requests themselves. (Utilization Mgmt. Operational Guideline at 1, ECF No. 102-29; Midkiff Dep. at 37-38, ECF No. 109-28.) NMMs of any level could also act as “preceptors,” making themselves available to answer questions from NMM trainees. (Mar. 18, 2024 Tr. at 90-91.) The National Committee for Quality Assurance (“NCQA”) sets uniform standards for utilization reviews and Defendants implemented policies to meet those standards. (See NCQA 2020 Utilization Mgmt. Standards and Elements, ECF No. 102-39.) Although the NCQA’s uniform standards do not dictate that utilization reviewers be RNs, Defendants required NMM Is, NMM IIs, and NMM Seniors to have RN licenses. (NCQA 2020 Utilization Mgmt. Standards and Elements at 19; ECF No. 109 { 36; Defs.’ Resp. to Pls.’ Req. for Admis. No. 5, ECF No. 102-3.) Plaintiffs allege that they routinely worked over forty (40) hours per week to complete assigned utilization reviews. (Second Am. Compl. § 5.) However, Plaintiffs did not receive overtime compensation because Defendants classified them as exempt

under the FLSA’s professional and administrative exemptions—which apply to certain employees whose roles require the use of judgment or discretion. (See id. {{] 59-60, 63.) B. Evidence on the NMM’s Use of Judgment and Discretion Valendez Gore, an RN and an opt-in member of the collective, testified during a deposition that she had been employed by Anthem as a utilization review nurse in the Nurse Medical Management Department. (Gore Dep. at 7-10, ECF No. 109-36.) She acknowledged that one of the Amerigroup Clinical Appropriateness Guidelines, which she used as part of her role, stated, “In all cases, clinical judgment consistent with the standards of good medical practice should be used when applying the guidelines.” (/d. at 32.) When asked, “So you used clinical judgment consistent with the standards of good medical practice when you were applying the guidelines?” Gore responded, “Yes.” (/d.) Gore also indicated that she “worked with the medical directors in interpreting appropriateness of care and accurate claims payments.” (Jd. at 28.) However, she also stated that Anthem’s practices would prohibit her from exercising independent clinical judgment. (/d. at 32.) For example, while she was permitted to approve authorization requests, she could not deny them. (/d.) During her deposition, Gore was asked about the guidelines that discussed whether

a member could complete activities of daily living (“ADLs”) and independent ADLs. (id. at 34-35.) These ADLs include tasks such as bathing, dressing, cleaning, and cooking. (/d.) Gore explained that “ADL” referred to the task in general and that the

term could imply a member required assistance when completing that task. (/d.) “Independent ADL” or “IADL” referred to tasks the member could finish without help.

(Id.) When asked how an RN newly hired as an NMM would know whether guidelines related to ADLs and independent ADLs were satisfied, Gore answered that an RN would already know that information due to his or her medical professional background. (Jd.) On a similar note, Gore described learning about pathophysiology in nursing school and stated that this background was important to her utilization review work. (/d. at 43-45.) Defendants deposed Pamela Hackett, an RN who was employed by Anthem as a utilization reviewer. (Hackett Dep. at 6-8, 34, ECF No. 109-30.) When asked whether the guidelines she used required utilization reviewers to exercise clinical judgment, she responded that although “someone on the outside reading it [the guidelines]” would think the guidelines require clinical judgment, the truth is that utilization reviewers cannot use clinical judgment when making determinations. (/d. at 33.) Hackett testified that “in reviewing cases with Anthem, it’s black and white” whether a request complies with the guidelines or not. (/d.) On September 25, 2023, Plaintiffs deposed Dalia Boral, a corporate representative for Anthem. (Boral Dep. at 1-2, ECF No. 109-34.) Boral stated that she is an RN, that she was previously employed as a utilization reviewer with Anthem, and that she was later promoted and became a manager overseeing other nurses who were utilization reviewers. (/d. at 2-5.) Speaking to how past claims are audited by Anthem, Boral testified that an auditor would review whether, “based on the clinical information, the

nurse utilized the correct criteria [a]nd then in using the criteria did they make the right decision to approve.” (/d.

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