Molly C. v. Oxford Health Insurance, Inc.

CourtDistrict Court, S.D. New York
DecidedNovember 21, 2024
Docket1:21-cv-10144
StatusUnknown

This text of Molly C. v. Oxford Health Insurance, Inc. (Molly C. v. Oxford Health Insurance, Inc.) is published on Counsel Stack Legal Research, covering District Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Molly C. v. Oxford Health Insurance, Inc., (S.D.N.Y. 2024).

Opinion

USDC SDNY DOCUMENT ELECTRONICALLY FILEI UNITED STATES DISTRICT COURT DOC #: SOUTHERN DISTRICT OF NEW YORK DATE FILED: _11/21/202¢ MOLLY C., etal., 21-CV-10144 (PGG) (BCM) Plaintiffs, -against- OPINION AND ORDER OXFORD HEALTH INSURANCE, INC., Defendant.

BARBARA MOSES, United States Magistrate Judge. Plaintiffs Molly C. and Naomi L. are beneficiaries of group health insurance plans administered by defendant Oxford Health Insurance, Inc. (Oxford). Beginning in 2019, plaintiffs were diagnosed with eating disorders, received outpatient nutritional counseling as part of their treatment, and submitted claims for that counseling to Oxford, which denied them on the ground that their plans did not cover those services. Because Oxford did cover nutritional counseling for diabetes, plaintiffs contend that its failure to do the same for eating disorders violated the Mental Health Parity and Addiction Equity Act (Parity Act), 29 U.S.C. § 1185a. By motion dated March 22, 2024, plaintiffs seek to certify a class consisting of all persons who were covered under an Oxford group health insurance plan in New York, were diagnosed with one of five specified eating disorders (EDs), received outpatient nutritional counseling from November 30, 2015 to the present (the Class Period), and either (a) submitted claims for that counseling, which Oxford denied on the ground that it was "not a covered benefit" (the Denied Claims Subclass), or (b) did not submit claims (the No Claims Subclass). In order to establish the required numerosity of each proposed subclass, plaintiffs rely on two expert declarations from Frank Fox, Ph.D., who estimates — based on claims data supplied by Oxford — that during the Class Period at least 458 Oxford members with EDs submitted at least 1,461 claims for outpatient nutritional counseling that were denied because the treatment was "not a covered benefit." Dr. Fox

also opines that, during the same period, 1,300 to 1,795 Oxford members per year would have received nutritional counseling for their EDs, had it been a covered benefit, and that 513 to 709 Oxford members per year actually did receive such treatment. Now before me, on referral from the Hon. Paul G. Gardephe, United States District Judge, is Oxford's motion, filed on May 10, 2024 (Dkt. 84), to exclude Dr. Fox's opinions pursuant to

Fed. R. Evid. 702 and the standards set forth in Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579 (1993) and its progeny.1 As to the Denied Claims Subclass, defendant primarily argues that Dr. Fox merely performed "simple mathematics" that did not require any specialized expertise. As to the No Claims Subclass, defendant argues that Dr. Fox's opinions are not relevant to numerosity, and are in any event inherently unreliable. After careful review of the parties' papers, I conclude that Dr. Fox's opinions are relevant to the pending certification motion and that defendant's reliability arguments go to their weight, not their admissibility. Moreover, because the challenged expert evidence is offered in support of class certification, as to which the District Judge is both gatekeeper and factfinder, "there is no risk

of jury confusion," Simmons v. Garland, 2024 WL 1468239, at *3 (E.D.N.Y. Mar. 20, 2024), and "all doubts should be resolved in favor of admissibility." Am. Empire Surplus Lines Ins. Co. v. J.R. Contracting & Env't Consulting, Inc., 2024 WL 3638329, at *4 (S.D.N.Y. Aug. 2, 2024) (internal quotation marks and citation omitted). Consequently, as explained in more detail below, defendant's motion will be denied.

1 Plaintiff's class certification motion remains pending before Judge Gardephe. However, defendant's Daubert motion is within my referral for general pretrial management (see Dkt. 60), made pursuant to 28 U.S.C § 636(b)(1)(A) and Fed. R. Civ. P. 72(a). See Israel v. Springs Indus., Inc., 2007 WL 9724896, at *2 (E.D.N.Y. July 30, 2007) (because a Daubert motion is "nondispositive of the litigation, disposition of it by a magistrate judge in the form of an order and not a Report and Recommendation is appropriate") (collecting cases); accord BS Pac. Life Ins. Co. v. Bank of New York Mellon, 571 F. Supp. 3d 106, 111 (S.D.N.Y. 2021). I. BACKGROUND A. Plaintiffs' Allegations Oxford issues and administers health insurance plans in New York, including group plans governed by the Employee Retirement and Income Security Act of 1974 (ERISA), 29 U.S.C. §§ 1001-1461, of which the Parity Act is a part. See Am. Compl. (Dkt. 35) ¶¶ 5, 12. Plaintiffs

Molly C. and Naomi L. are beneficiaries of ERISA-governed group health insurance plans administered by Oxford in New York. Id. ¶¶ 15, 20, 23, 44. Starting in 2019, they received treatment for EDs, including outpatient nutritional counseling. Id. ¶¶ 28-30, 49-50. However, Oxford rejected their counseling claims on the ground that those services were "not a covered benefit" under their plans. Id. ¶¶ 30-31, 50-51, 55. As a result, both plaintiffs (or their parents) were required to pay out of pocket for their treatment. Id. ¶¶ 41, 56. The Oxford plans did, however, cover outpatient nutritional counseling for members diagnosed with "physical conditions such as diabetes." Id. ¶ 4; see also id. ¶¶ 27, 42, 47, 57. Thus, plaintiffs allege, Oxford violated the Parity Act's requirement that "benefits for mental health treatment [be] no more restrictive than benefits for medical and surgical treatment." Id. ¶ 25 (citing 29 U.S.C. § 1185a(a)(3)(A)).

Defendant admits that, "[p]rior to January 2021, Oxford plans issued in New York did not expressly provide general coverage for nutritional counseling services," Def. Class Cert. Opp. (Dkt. 95) at 2, and that Oxford denied some of the claims submitted by Molly C. and Naomi L. on the ground that outpatient nutritional counseling for EDs was not a covered service. Id. at 5, 6-7. In April 2021, Oxford "reconfigured its claims processing system to consistently provide coverage, and pay claims, for nutritional counseling for eating disorders with dates of service on or after January 1, 2021." Id. at 3. However, Oxford "could not" and did not "change the language of its written plan documents," which did not list outpatient nutritional counseling as a covered benefit for mental health conditions, until 2023. Id. at 3-4. B. The Class Definition In their operative complaint, filed on behalf of the named plaintiffs and "all others similarly situated," Am. Compl. ¶ 68, plaintiffs define a single proposed class, consisting of all persons covered under a group health insurance plan administered by Oxford in New York who were diagnosed with an ED "and whose request for authorization or claim for reimbursement for

nutritional counseling or dietician services was made between November 30, 2015 and the present . . . and was denied." Id. ¶ 69.

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Bluebook (online)
Molly C. v. Oxford Health Insurance, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/molly-c-v-oxford-health-insurance-inc-nysd-2024.