Molina Healthcare of Texas, Inc. v. ACS Primary Care Physicians Southwest, PA and Emergency Services of Texas, PA

CourtCourt of Appeals of Texas
DecidedAugust 1, 2024
Docket01-21-00727-CV
StatusPublished

This text of Molina Healthcare of Texas, Inc. v. ACS Primary Care Physicians Southwest, PA and Emergency Services of Texas, PA (Molina Healthcare of Texas, Inc. v. ACS Primary Care Physicians Southwest, PA and Emergency Services of Texas, PA) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Molina Healthcare of Texas, Inc. v. ACS Primary Care Physicians Southwest, PA and Emergency Services of Texas, PA, (Tex. Ct. App. 2024).

Opinion

Opinion issued August 1, 2024

In The

Court of Appeals For The

First District of Texas ———————————— NO. 01-21-00727-CV ——————————— MOLINA HEALTHCARE OF TEXAS, INC., Appellant V. ACS PRIMARY CARE PHYSICIANS SOUTHWEST, PA AND EMERGENCY SERVICES OF TEXAS, PA, Appellees

On Appeal from the 113th District Court Harris County, Texas Trial Court Case No. 2017-777084

MEMORANDUM OPINION

This case involves a dispute over reimbursement rates for doctors who

provided out-of-network emergency medical care to a health insurance company’s

insureds. Appellees ACS Primary Care Physicians Southwest, PA and Emergency Services of Texas, PA (collectively, “the providers”) asserted claims against

appellant Molina Healthcare of Texas, Inc. (“Molina”) for a violation of Insurance

Code section 1271.155(a) relating to payment for emergency care performed by non-

network physicians, violation of the Insurance Code’s prohibition against unfair

claim settlement practices, breach of an implied-in-fact contract, and quantum

meruit.

A jury found in favor of the providers on all their asserted claims and awarded

damages. The trial court entered judgment on the jury verdict and awarded the

providers approximately $1.6 million in actual damages and $3.1 million in treble

damages under the Insurance Code. The parties agreed to submit the issue of

attorney’s fees to the trial court, and the court awarded approximately $5.1 million

in trial-level attorney’s fees and $430,000 in conditional appellate attorney’s fees.

While this case was pending on appeal, the Texas Supreme Court issued an

opinion holding that (1) no private right of action exists under Insurance Code

section 1271.155(a), (2) emergency care providers may not use the prohibitions

against unfair settlement practices under Insurance Code chapter 541 to raise a claim

that an insurance company underpaid reimbursement rates under section

1271.155(a), and (3) emergency care providers cannot maintain a claim against an

insurance company for quantum meruit. See Tex. Med. Res., LLP v. Molina

Healthcare of Tex., Inc., 659 S.W.3d 424 (Tex. 2023). The parties agree that as a

2 result of this decision, the providers cannot recover under these three claims, and

these claims are therefore no longer at issue in this appeal.

In its remaining two arguments, Molina contends that (1) the providers’ claim

for breach of an implied contract is an impermissible repackaging of claims the

Texas Supreme Court has held cannot be brought against insurers and no evidence

supports this claim because there is no evidence of a meeting of the minds, no

evidence of consideration, and no evidence of breach of an implied contract; and

(2) the providers cannot recover attorney’s fees on their claim for breach of an

implied contract.

We reverse and render judgment.

Background

A. Relationship Between the Parties and the Relevant Regulatory Scheme

Molina is a health maintenance organization (“HMO”) that offers a variety of

health insurance plans to its insureds, including commercial plans through the

federal exchange established by the Patient Protection and Affordable Care Act

(“ACA”). Molina’s ACA plans are the health insurance plans involved in this case.

ACS Primary Care Physicians Southwest, PA (“ACS”) is a “professional

emergency medicine services group practice” that staffs emergency departments at

hospitals and medical centers throughout Texas, including eight hospitals in the

Memorial Hermann system in the Houston area. Emergency Services of Texas, PA

3 (“Emergency Services”) staffs emergency departments at hospitals primarily in the

El Paso area. Neither ACS nor Emergency Services has an express contract with

Molina setting out agreed reimbursement rates for emergency care provided to

Molina’s insureds. The providers are therefore “out of network” with Molina.

Both federal and state law require hospitals to provide stabilizing emergency

care for patients regardless of the patient’s insurance status or ability to pay. See 42

U.S.C. § 1395dd(b), (c); TEX. HEALTH & SAFETY CODE §§ 241.027–.028, 311.022;

Tex. Med. Res., 659 S.W.3d at 427. Insurance Code section 1271.155(a) provides

that an HMO such as Molina “shall pay for emergency care performed by non-

network physicians or providers at the usual and customary rate or at an agreed rate.”

TEX. INS. CODE § 1271.155(a). The statute does not define “usual and customary

rate.” The HMO’s health care plan must provide coverage for “necessary emergency

care,” including “the treatment and stabilization of an emergency medical

condition.” Id. § 1271.155(b). The health care plan “shall comply with this section

regardless of whether the physician or provider furnishing the emergency care has a

contractual or other arrangement with the [HMO] to provide items or services to

covered enrollees.” Id. § 1271.155(e).

In 2019, the Texas Legislature amended multiple provisions of the Insurance

Code to address, among other things, how to resolve payment disputes between out-

of-network emergency care providers and HMOs. See Tex. Med. Res., 659 S.W.3d

4 at 428. The new provisions include “a mandatory binding arbitration process for

disputes between an insurer and an out-of-network emergency-care physician over

the amount the insurer must pay the physician for care rendered to an individual

enrolled in the insurer’s plan.” Id.; see TEX. INS. CODE §§ 1467.081–.089. An out-

of-network provider or an insurance company may not file suit for an out-of-network

claim until after the conclusion of the arbitration proceeding on the issue. Tex. Med.

Res., 659 S.W.3d at 428–29; TEX. INS. CODE § 1467.085(a). This arbitration process,

however, only applies to health care services rendered on or after January 1, 2020.

Tex. Med. Res., 659 S.W.3d at 429; Act of May 24, 2019, 86th Leg., R.S., ch. 1342,

§ 5.01, 2019 Tex. Gen. Laws 3940, 3963. It is undisputed that this lawsuit does not

involve health care services rendered on or after January 1, 2020. At the time the

providers rendered the services at issue in this dispute, no court had opined on the

remedies available to an out-of-network provider alleging underpayment by an

HMO for emergency care services.

B. Procedural Background

The providers filed the underlying lawsuit in November 2017. The providers

alleged that between January 2016 and August 2019, they provided emergency

medical services to Molina insureds, and they directly billed Molina for payment of

over 13,000 claims arising from these services. The providers billed Molina

$19,373,648.

5 Molina determined that all claims at issue involved medically necessary,

covered health care services, and therefore the claims were payable. However,

Molina allegedly paid the providers “at rates substantially less than both [the

providers’] billed charges and the ‘usual and customary rate’ in [the providers’]

geographic area.” Molina paid the providers $2,115,932. The providers alleged that

they had suffered damages “in an amount equal to the difference between the

amounts allowed as payable by Molina and the lesser of [the providers’] charges and

the ‘usual and customary rate’ for professional emergency medicine services in the

same geographic area, plus [the providers’] loss of use of that money.”

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Molina Healthcare of Texas, Inc. v. ACS Primary Care Physicians Southwest, PA and Emergency Services of Texas, PA, Counsel Stack Legal Research, https://law.counselstack.com/opinion/molina-healthcare-of-texas-inc-v-acs-primary-care-physicians-southwest-texapp-2024.