Prescription Partners, LLC v. Bureau of Workers' Compensation Fee Review Hearing Office (Healthsmart Casualty Claims Solutions)

CourtCommonwealth Court of Pennsylvania
DecidedSeptember 30, 2015
Docket2108 C.D. 2014
StatusUnpublished

This text of Prescription Partners, LLC v. Bureau of Workers' Compensation Fee Review Hearing Office (Healthsmart Casualty Claims Solutions) (Prescription Partners, LLC v. Bureau of Workers' Compensation Fee Review Hearing Office (Healthsmart Casualty Claims Solutions)) is published on Counsel Stack Legal Research, covering Commonwealth Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Prescription Partners, LLC v. Bureau of Workers' Compensation Fee Review Hearing Office (Healthsmart Casualty Claims Solutions), (Pa. Ct. App. 2015).

Opinion

IN THE COMMONWEALTH COURT OF PENNSYLVANIA

Prescription Partners, LLC, : Petitioner : : v. : No. 2108 C.D. 2014 : Submitted: July 17, 2015 Bureau of Workers’ Compensation : Fee Review Hearing Office : (Healthsmart Casualty Claims : Solutions), : Respondent :

BEFORE: HONORABLE RENÉE COHN JUBELIRER, Judge HONORABLE P. KEVIN BROBSON, Judge HONORABLE ROCHELLE S. FRIEDMAN, Senior Judge

OPINION NOT REPORTED

MEMORANDUM OPINION BY JUDGE BROBSON FILED: September 30, 2015

Prescription Partners, LLC (Prescription Partners) filed a petition for review of an order of a Bureau of Workers’ Compensation (Bureau) Fee Review Hearing Officer (Hearing Officer), denying and dismissing Prescription Partners’ request for a hearing. For the reasons discussed below, we vacate the order and remand for proceedings consistent with this opinion. The facts of this case are not in dispute. Carol Stotka (Claimant), an employee of St. Paul Surety (Employer), suffered a work-related injury on September 27, 1990. Claimant receives treatment for her injury, a chronic pain condition, from Dr. Michael Toshok (Provider). As part of Claimant’s treatment, Provider dispensed two prescription medications1 out of his office. Provider obtained these medications from an unknown vendor who, prior to giving them to Provider, had repackaged the medications. Because the vendor repackaged the medications, each medication had two packaging or NDC codes: one from the manufacturer (original manufacturer NDC code or OMNDC code) and a repackaged NDC code. Provider did not bill Employer directly for the medications dispensed to Claimant but instead assigned the claim to Prescription Partners. Prescription Partners then billed Employer, a self-insured entity, and its third-party administrator, Healthsmart Casualty Claims Solutions (Healthsmart), a total of $1,177.16 for the two medications. Prescription Partners arrived at this total by calculating 110% of the average wholesale price (AWP)2 of each medication based upon the repackaged NDC code. After reviewing the claim, Healthsmart reimbursed Prescription Partners for $1,018.94, an amount equal to 110% of the AWP of each medication based upon the OMNDC code. After receiving the partial payment from Healthsmart, Prescription Partners filed an application for fee review with the Bureau. The Bureau’s Medical Fee Review Section determined that Prescription Partners was not entitled to any additional compensation from Healthsmart because Prescription Partners, as

1 The prescription medications dispensed by Provider to Claimant are Cyclobenzaprine HCL and Lidoderm Patches. 2 The workers’ compensation regulations provide that “[w]hen a prescription is filled at a physician’s office, payment for the prescription drug shall be limited to 110% of the average wholesale price of the product.” 34 Pa. Code § 127.135(a).

2 a third party, was not entitled to reimbursement. Prescription Partners then filed a request for a fee review hearing to contest the adverse determination. At a hearing held July 17, 2014, Healthsmart presented the testimony of Mr. William Jobes. Mr. Jobes testified that Healthsmart uses the “original NDC number” when paying claims. (Reproduced Record (R.R.) 29a.) When asked on cross-examination to identify the regulation that required the OMNDC code be used, Mr. Jobes was unable to do so. (R.R. 30a.) Wendy Caldera, the manager of Prescription Partners’ billing department, testified that Prescription Partners uses the Thompson Reuters Red Book (Red Book), the schedule of AWPs used in Pennsylvania, to determine 110% of the AWP for any medications dispensed by Provider. (R.R. 34a.) She also testified that she was unaware of any regulation which required the OMNDC code to be used to determine the AWP. (R.R. 34a.) During cross-examination, Ms. Caldera testified that Prescription Partners acts only as a “billing service.” (R.R. 35a.) She further testified that Prescription Partners did not provide prescription medication or healthcare services, but, instead, it purchased the claim from the Provider. (R.R. 35-36a.) In his decision, the Hearing Officer noted that there were only two issues, both of them questions of law: (1) whether Prescription Partners, as an assignee of Provider, had standing to file the fee review application, and (2) whether the proper amount for reimbursement for a repackaged drug is based upon the OMNDC code or the repackaged NDC code. (R.R. 6a.) As to the first issue, the Hearing Officer found that “Prescription Partners is not a provider of healthcare services. It is, instead, an assignee of the provider.” (R.R. 9a.) The

3 Hearing Officer then concluded that as an assignee, Prescription Partners had no standing to request the fee review: The party requesting review, Prescription Partners, has failed to meet the burden of proof required to demonstrate that it is a proper party. Prescription Partners has failed to meet the burden of proof required to establish that it was a party competent either to file an original Application for Fee Review or a Request for de novo appeal therefrom. The applicable provision of the law, and its corresponding regulation, grant only to providers, not assignees, the right to file an Application for a Fee Review. Section 306(5) of the [Workers’ Compensation] Act (Act), [Act of June 2, 1915, P.L. 736, as amended,] 77 P.S. § 531(5).[3] A provider, also known as healthcare provider, is defined in the regulations as follows: “A person, corporation, facility or institution licensed, or otherwise authorized, by the Commonwealth, to provide healthcare services, including physicians . . ., pharmacists, and officers, employees or agents of the person acting in the course and scope of employment or agency related to healthcare services.”[4] No mention is made in this definition of an assignee. It is specifically concluded as a matter of law, in this regard, that an assignee is not an agent of the healthcare provider in the present case. An agent is an individual or entity that acts on behalf of a provider or other party. An assignee is a claim holder in its own right.

3 Section 306(5) of the Act provides, in pertinent part: “A provider who has submitted the reports and bills required by this section and who disputes the amount or timeliness of the payment from the employer or insurer shall file an application for fee review with the department . . . .” The corresponding regulation likewise provides: “A provider who has submitted the required bills and reports to an insurer and who disputes the amount or timeliness of the payment made by an insurer, shall have standing to seek review of the fee dispute by the Bureau.” 34 Pa. Code § 127.251. 4 34 Pa. Code § 127.3.

4 Prescription Partners has no standing in this forum. (R.R. 9-10a (second to last alteration in original).) The Hearing Officer also concluded that any assignment of Provider’s claim to Prescription Partners was in violation of Section 318 of the Act, Act of June 2, 1915, P.L. 736, as amended, 77 P.S. § 621. Section 318 of the Act provides, in pertinent part, that “[c]laims for payments due . . . shall not be assignable.” As to the second issue, the Hearing Officer found that in billing [Employer/Healthsmart] the amount of $1,177.16, Prescription Partners was, indeed, using a repackaged drug NDC code, deriving the [AWP] of same, and then adding 10%. It is similarly found . . . that the amount paid by [Employer] was indeed $1,018.94. It is found as fact . . . that this was a correct amount when applying the original manufacturer NDC codes and the amounts derived with regard thereto from the Red Book for such original manufacturer packaging. (R.R. 9a.) The Hearing Officer then concluded that Healthsmart was only liable for “the original manufacturer average wholesale price, and not for the amount corresponding to the repackaged number.” (R.R.

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Prescription Partners, LLC v. Bureau of Workers' Compensation Fee Review Hearing Office (Healthsmart Casualty Claims Solutions), Counsel Stack Legal Research, https://law.counselstack.com/opinion/prescription-partners-llc-v-bureau-of-workers-compensation-fee-review-pacommwct-2015.