Osinek v. Kaiser Permanente

District Court, N.D. California·Decided November 14, 2022·No. 3:13-cv-03891·Unknown

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 UNITED STATES OF AMERICA ex rel. Case No. 13-cv-03891-EMC RONDA OSINEK, 8 CONSOLIDATED MEMBER CASES Plaintiff,

9 v. Case No. 16-cv-01558-EMC 10 Case No. 16-cv-05337-EMC PERMANENTE MEDICAL GROUP, INC, Case No. 18-cv-01347-EMC 11 et al., Case No. 21-cv-03124-EMC Case No. 21-cv-03894-EMC 12 Defendants. ORDER GRANTING IN PART AND 13 DENYING IN PART DEFENDANTS’ MOTION TO DISMISS TAYLOR’S 14 SECOND AMENDED COMPLAINT WITH LEAVE TO AMEND 15 Docket No. 181 16 17 18 The above-referenced case consists of several consolidated cases that charge Kaiser 19 entities with making false claims for payment to the federal government. The main claims 20 asserted against the Kaiser entities are violations of the federal False Claims Act (“FCA”). 21 Following the Court’s order of May 5, 2022, see Docket No. 171 (order), the following cases 22 remain: 23 (1) The United States’ complaint in intervention (Docket No. 110); 24 (2) The first amended complaint in Osinek (Docket No. 87); 25 (3) Parts of the second amended complaint in Taylor (Docket No. 118); and 26 (4) Parts of the first amended complaint in Bryant (Docket No. 117).1 27 1 Currently pending before the Court are four motions to dismiss filed by the relevant Kaiser 2 entities. The motions are targeted at all of the cases that remain. This memo addresses only the 3 motion to dismiss the operative complaint in Taylor. Having considered the parties’ briefs, as well 4 as the oral as the oral argument of counsel, the Court hereby GRANTS the motion to dismiss but 5 gives Dr. Taylor leave to amend. 6 I. FACTUAL & PROCEDURAL BACKGROUND 7 A. Prior Order 8 Previously, the Court issued an order addressing the Kaiser entities’ argument that, inter 9 alia, the Taylor case was prohibited by the FCA’s first-to-file bar. See Docket No. 171 (order); 10 see also 31 U.S.C. § 3730(b)(5) (providing that, “[w]hen a person brings an action under this 11 subsection, no person other than the Government may intervene or bring a related action based on 12 the facts underlying the pending action”) (emphasis in original). In that order, the Court compared 13 the original complaint in Taylor to the complaint in Osinek that was operative at the time that 14 Taylor was filed. 15 The original complaint in Taylor identified three categories of conduct by Kaiser as 16 problematic: 17 (1) Kaiser failed to act even after audits revealed high error rates in risk adjustment 18 claims for certain HCCs (Hierarchical Conditions Categories) or diagnoses (in 19 particular, high-value conditions). 20 (2) Kaiser failed to act even after audits revealed high error rates for diagnoses made 21 by external providers (e.g., outside hospitals who provided care to Kaiser’s 22 members); and 23 (3) Kaiser failed to act even after audits revealed high error rates for “True Positive” 24 results associated with Kaiser’s Natural Language Processing (“NLP”) program. 25 The Court found that categories (2) and (3) were not barred by Osinek. However, part of 26 Claims Act. See Docket No. 171 (Order at 46). However, prior to the Court’s order, the plaintiff 27 in Bicocca had dismissed those state law claims. See Docket No. 159 (notice of voluntary partial 1 (1) was barred – specifically, to the extent the failure to act was associated with California. See 2 Docket No. 171 (Order at 34-35) (noting that, “[a]though Dr. Taylor is correct that his claim here 3 is about Kaiser ignoring an upcoding problem (as revealed by error rates) rather than actively 4 creating upcoding [which was Osinek’s focus], the Court does not see this flip side as creating a 5 material difference with respect to Osinek”; “both Taylor and Osinek are ultimately based on the 6 same ‘underlying facts’: that the high-level condition that was diagnosed did not have 7 documentation or proper support and/or did not affect patient care”). Osinek did not bar claims 8 based on the failure to act outside of California (nationwide). See Docket No. 171 (Order at 29, 9 32) (noting that the defendants in Taylor were essentially nationwide; because Osinek was 10 California-centric, “Taylor is broader in scope . . . in terms of defendants”). 11 B. Operative Complaint in Taylor 12 Although the Court found that Taylor was not barred in its entirety, the Court’s focus at 13 that point was on the original complaint in Taylor. Now pending before the Court is a motion to 14 dismiss the operative complaint in Taylor which is the second amended complaint (“SAC”). 15 The factual allegations in the Taylor SAC are largely the same as those contained in the 16 original Taylor complaint. To wit, as alleged, Defendants engaged in three categories of 17 misconduct: 18 (1) Internal provider theory. Defendants’ audits put them on notice of high error 19 rates with respect to the coding of certain high-value conditions by internal 20 providers. See Taylor SAC ¶ 140. Some of the audits also revealed the reason for 21 the errors. See, e.g., Taylor SAC ¶ 216 (“In its probe audits, Kaiser found that false 22 claims were routinely submitted to CMS where the diagnosis was listed in medical 23 documentation of a physician or hospital outpatient visit as probable, ruled out, or 24 suspected. CMS rules prohibit the use of such a diagnosis for a risk adjustment 25 claim.”). In spite of knowing about the error rates and the fact that there were 26 errors, Defendants “refused to take corrective action.” Taylor SAC ¶ 201; see also 27 Taylor SAC ¶ 146. 1 error rates in risk adjustment claims based on diagnoses provided by external 2 providers. See Taylor SAC ¶ 105. In 2009, Defendants began a project that 3 involved retrospective chart review of external provider diagnoses. See Taylor 4 SAC ¶ 120. Coders reviewed records from the external providers looking for 5 diagnoses supported by documentation. See Taylor SAC ¶ 120. Defendants 6 “treated the results differently depending on whether they would generate revenue.” 7 Taylor SAC ¶ 121. They would give to CMS only those “codes that had not 8 previously been coded by the treating physician[s]” because this would “yield[] 9 additional payments to [Defendants],” Taylor SAC ¶ 121; otherwise, Defendants 10 did nothing – i.e., they did not take corrective action with respect to findings that 11 diagnosis codes were not supported by the medical records. See Taylor SAC ¶ 125. 12 (3) NLP/True Positive theory. A NLP program uses an algorithm to search electronic 13 medical records to find words indicating that a patient has certain diagnoses. See 14 Taylor SAC ¶ 224. A NLP program can be used “to try to find new diagnosis 15 codes to submit.” Taylor SAC ¶ 224. “[A] good NLP program can also identify 16 situations where a diagnosis was submitted . . . but is not documented in the 17 medical record.” Taylor SAC ¶ 225. In 2009, Kaiser built its own NLP program 18 (even though other companies offer such products). See Taylor SAC ¶ 224. The 19 program grouped results into four categories: “(a) True Positive: diagnoses that 20 have been confirmed by two Kaiser coders; (b) More Information Needed: 21 diagnoses that may be present, but further analysis is required to confirm; (c) 22 Problem List Only: diagnoses that show up only on the member’s problem list [in 23 the medical records] with no documentation of treatment; and (d) False Positives or 24 Found Elsewhere.” Taylor SAC ¶ 229. Although True Positives have diagnoses 25 confirmed by two coders, they actually have high error rates. See, e.g., Taylor SAC 26 ¶ 232 (alleging that Dr. Taylor “personally reviewed over 100 of the supposedly 27 ‘True Positive’ claims for the Colorado region and found a 10% error rate[;] [i]n 1 reviewing coders have validated, diagnoses that appear in problem lists but which 2 lack additional notation of treatment”).

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