Pacific Recovery Solutions v. United Behavioral Health

CourtDistrict Court, N.D. California
DecidedAugust 25, 2020
Docket4:20-cv-02249
StatusUnknown

This text of Pacific Recovery Solutions v. United Behavioral Health (Pacific Recovery Solutions v. United Behavioral Health) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Pacific Recovery Solutions v. United Behavioral Health, (N.D. Cal. 2020).

Opinion

1 2 3 IN THE UNITED STATES DISTRICT COURT 4 FOR THE NORTHERN DISTRICT OF CALIFORNIA 5 CASE NO. 4:20-cv-02249 YGR 6 PACIFIC RECOVERY SOLUTIONS, ET AL., ORDER GRANTING MOTIONS TO 7 Plaintiffs, DISMISS WITH LEAVE TO AMEND

8 v. Re: Dkt. Nos. 38, 39 9 UNITED BEHAVIORAL HEALTH, ET AL., 10 Defendants. 11

12 Plaintiffs1 bring this putative class action against defendants United Behavioral Health 13 (“United”) and Viant, Inc. for claims arising out of United’s alleged failure to reimburse plaintiffs 14 “a percentage” of the Usual, Customary, and Reasonable Rates (“UCR”) for Intensive Outpatient 15 Program (“IOP”) services, which plaintiffs provided to patients with health insurance policies 16 administered by United. In the complaint, plaintiffs assert, on their own behalf and on behalf of a 17 proposed class of similarly-situated out-of-network IOP providers, claims under Section 1 of the 18 Sherman Act and the Racketeer Influenced and Corrupt Organizations Act (“RICO”), and multiple 19 claims under California law. 20 Now pending are two motions to dismiss all claims in the complaint under Federal Rule of 21 Civil Procedure 12(b)(6) on the grounds that: (1) plaintiffs’ claims under Section 1 of the Sherman 22 Act and RICO fail for lack of statutory standing; (2) plaintiffs’ state-law claims are preempted by 23 the Employee Retirement Income Security Act of 1974 (“ERISA”); and (3) all claims in the 24 complaint are inadequately pleaded. 25 26

27 1 Plaintiffs are Pacific Recovery Solutions d/b/a Westwind Recovery, Miriam Hamideh 1 Having carefully considered the pleadings and the parties’ briefs, and for the reasons set 2 forth below, the Court GRANTS the motions to dismiss WITH LEAVE TO AMEND. 3 I. BACKGROUND 4 Plaintiffs allege as follows. Plaintiffs are out-of-network healthcare providers who 5 provided IOP services to patients who had health insurance policies that United administered. 6 Compl. ¶ 2, Docket No. 1. Before providing treatment to these patients, “each of the Plaintiffs 7 confirmed with United that the patients had active coverage and benefits for out of network IOP 8 treatment services” through verification-of-benefits (“VOB”) calls, during which United 9 “represented” that it would pay the patients’ claims in connection with such services. Id. ¶¶ 3, 17, 10 188, 195, 202, 209. The complaint references payment both “at a percentage” of the UCR and “at 11 the UCR rate.” See, e.g., id. ¶¶ 16, 25, 74. Due to the communications in question, plaintiffs and 12 United “understood” UCR to be “consistent with United’s published definition of UCR rates.” Id. 13 ¶ 324; id. ¶ 17 n.6 (alleging that United published a definition of UCR on its webpage describing 14 out-of-network benefits). Thus, plaintiffs provided IOP services to the patients in reliance of 15 United’s representations. Id. ¶¶ 3, 17, 188, 195, 202, 209. 16 United’s representations that it would pay a percentage of the UCR were false, because 17 “United did not pay UCR amounts for any of the patient claims at issue in this litigation.” Id. ¶ 18 13. Instead, United engaged defendant Viant, a third-party “repricer,” to “negotiate” 19 reimbursements with Plaintiffs. Id. United has a contract with Viant pursuant to which Viant has 20 “financial incentives” to negotiate reimbursements “at well below the UCR rate.” Id. ¶ 33. 21 During its negotiations with plaintiffs, Viant represented that it had authority to negotiate with 22 providers on the patients’ behalf and that “the rate it offers is based on the UCR for the provider’s 23 geographic location.” Id. ¶¶ 34, 48, 52. Viant’s negotiations with plaintiffs resulted in offers to 24 reimburse them for IOP services at an amount below the UCR, and United paid the patients’ 25 claims at the “reduced Viant amount.” Id. ¶¶ 13-14. Neither United nor Viant disclosed to 26 Plaintiffs the methodology they used for calculating the reimbursement rates for IOP services. Id. 27 ¶ 54. United “unjustly retained” the difference between the amounts it “should have paid” to 1 plaintiffs for the IOP services at issue and the amount that United actually did pay based on 2 Viant’s negotiated reimbursements. Id. ¶ 15. 3 “[L]iability for the cost of care” that plaintiffs provided to patients ultimately falls on the 4 patients. Id. ¶¶ 55, 155, 4. Plaintiffs “make every effort to recover unpaid amounts, first from 5 United, then from patients.” Id. ¶ 55. Plaintiffs “balance bill” patients for the amounts that the 6 patients owe after taking into account any amounts that United reimbursed. Id. ¶¶ 155, 4. 7 Further, United and other insurers were required as part of the settlement of an unrelated 8 litigation (“Ingenix litigation”) to underwrite the creation of a database called the “FAIR health” 9 database, which contains rates for the reimbursement for IOP treatment. Id. ¶ 20. However, 10 United and the other insurers were not required by the Ingenix litigation settlement to use the 11 FAIR health database.2 Id. 12 Plaintiffs assert the following claims on their own behalf and on behalf of a proposed class 13 of similarly-situated out-of-network IOP providers in the United States: (1) a claim for violations 14 of the Unfair Competition Law (“UCL”), Bus. & Prof. Code § 17200 et seq.; (2) intentional 15 misrepresentation and fraudulent inducement; (3) negligent misrepresentation; (4) civil 16 conspiracy; (5) breach of oral or implied contract; (6) promissory estoppel; (7) a claim under 17 RICO, 18 U.S.C. § 1962(c); and (8) a claim under Section 1 of the Sherman Act, 15 U.S.C. § 1. 18 II. LEGAL STANDARD 19 To survive a Rule 12(b)(6) motion to dismiss, a complaint must contain sufficient factual 20 matter that, when accepted as true, states a claim that is plausible on its face. Ashcroft v. Iqbal, 21 556 U.S. 662, 678 (2009). “A claim has facial plausibility when the plaintiff pleads factual 22 content that allows the court to draw the reasonable inference that the defendant is liable for the 23 misconduct alleged.” Id. While this standard is not a probability requirement, “[w]here a 24 complaint pleads facts that are merely consistent with a defendant’s liability, it stops short of the 25 line between possibility and plausibility of entitlement to relief.” Id. (internal quotation marks and 26

27 2 Plaintiffs argue in their opposition that United represented to them that it would 1 citation omitted). In determining whether a plaintiff has met this plausibility standard, the Court 2 must “accept all factual allegations in the complaint as true and construe the pleadings in the light 3 most favorable” to the plaintiff. Knievel v. ESPN, 393 F.3d 1068, 1072 (9th Cir. 2005). “[A] 4 court may not look beyond the complaint to a plaintiff’s moving papers, such as a memorandum in 5 opposition to a defendant’s motion to dismiss.” Schneider v. California Dep’t of Corr., 151 F.3d 6 1194, 1197 n.1 (9th Cir. 1998). A court should grant leave to amend unless “the pleading could 7 not possibly be cured by the allegation of other facts.” Cook, Perkiss & Liehe, Inc. v. N. Cal. 8 Collection Serv. Inc., 911 F.2d 242, 247 (9th Cir. 1990). 9 III. DISCUSSION 10 As noted, defendants move to dismiss all claims in the complaint on the grounds that (1) 11 plaintiffs’ claims under Section 1 of the Sherman Act and RICO fail for lack of statutory standing; 12 (2) plaintiffs’ state-law claims are preempted by ERISA; and (3) all claims in the complaint are 13 inadequately pleaded. 14 The Court addresses each of these arguments in turn. 15 A.

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Bluebook (online)
Pacific Recovery Solutions v. United Behavioral Health, Counsel Stack Legal Research, https://law.counselstack.com/opinion/pacific-recovery-solutions-v-united-behavioral-health-cand-2020.