RJ v. Cigna Behavioral Health, Inc.

CourtDistrict Court, N.D. California
DecidedSeptember 2, 2022
Docket5:20-cv-02255
StatusUnknown

This text of RJ v. Cigna Behavioral Health, Inc. (RJ v. Cigna Behavioral Health, Inc.) 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
RJ v. Cigna Behavioral Health, Inc., (N.D. Cal. 2022).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 SAN JOSE DIVISION 7 RJ, as the representative of her beneficiary 8 son, SJ; LW, as the representative of her Case No. 5:20-cv-02255-EJD beneficiary spouse MW; and DS, an 9 individual, and on behalf of themselves and ORDER GRANTING IN PART AND all others similarly situated, DENYING IN PART DEFENDANTS’ 10 MOTIONS TO DISMISS FIRST Plaintiffs, AMENDED COMPLAINT 11 v. Re: Dkt. Nos. 75, 76 12 CIGNA HEALTH AND LIFE 13 INSURANCE COMPANY, et al., 14 Defendants.

15 In this putative class action suit, Plaintiffs challenge Defendant Cigna Behavioral Health, 16 Inc.’s alleged failure to reimburse covered mental health provider claims at the usual, customary, 17 and reasonable (“UCR”) rates. Presently before the Court are two motions to dismiss the First 18 Amended Class Action Complaint (“FAC”); one brought by Cigna Health and Life Insurance 19 Company (“Cigna”), and a separate motion brought by Defendant MultiPlan, Inc. (“MultiPlan”) 20 (collectively referred to as “Defendants”).1 Dkt. Nos. 75, 76. Plaintiffs filed oppositions (Dkt. 21 Nos. 79-81) and Defendants filed replies (Dkt. Nos. 88, 89). The Court finds these matters 22 suitable for disposition without oral argument pursuant to Civil Local Rule 7-1(b). For the reasons 23 stated below, Defendants’ motions will be granted in part and denied in part. 24 25

26 1 Plaintiffs previously named different Defendants: Viant, Inc. (“Viant”), MultiPlan Corp., and Cigna Behavioral Health, Inc. Pursuant to the Joint Stipulation and Order to Substitute and 27 Dismiss Defendants, MultiPlan and Cigna were substituted into the case. Dkt. No. 69. Case No.: 5:20-cv-02255-EJD 1 I. BACKGROUND2 2 Plaintiff RJ is a participant in an employee benefits plan subject to the Employee 3 Retirement Income Security Act of 1974 (“ERISA”), which is sponsored and funded by “Inuit, 4 Inc.” FAC ¶ 38. RJ is the parent of her beneficiary son, SJ, who is also a behavioral health 5 patient. Id. Plaintiff LW is a participant in an employee benefits plan subject to ERISA, which is 6 sponsored and funded by International Paper Co. Id. ¶ 39. LW is the spouse of plan beneficiary, 7 MW, who is a behavioral health patient. Id. Plaintiff DS is a participant in an employee benefits 8 plan subject to ERISA, which is sponsored and funded by Impossible Foods, Inc. Id. ¶ 40. DS is 9 also a behavioral health patient. Id. Cigna is responsible for the administration and payment of 10 claims for behavioral services covered under health plans sponsored or administered by Cigna 11 Corporation or its many wholly owned and controlled subsidiaries, including Cigna Behavioral 12 Health. Id. ¶ 42. Plaintiffs were all members of policies offering out of network (“OON”) 13 benefits which Cigna either sold and underwrote or administered on behalf of employers. Id. ¶ 56. 14 MultiPlan is a Delaware corporation with a business address in New York. Id. ¶ 43. Viant is a 15 Nevada corporation and wholly owned subsidiary of MultiPlan. Id. 16 Summit Estate, Inc. (“Summit Estate”) contacted Cigna to verify coverage before 17 providing treatment (“VOB” calls). A Cigna representative confirmed that RJ’s son, SJ, had 18 coverage through an “MRC-1” plan, with benefits covered at the 80th percentile of charges for 19 similar services in the same geographic area. Id. ¶278. A Cigna representative confirmed MW’s 20 and DS’s plans were “MRC-2” policies and verified that claims would be paid at 150% and 110%, 21 respectively, of the Medicare-based schedule rate for all services. Id. ¶¶ 310, 340. There is, 22 however, no Medicare schedule rates for the substance use disorder services MW and DS were to 23 receive. The MRC-2 policy provides that where a Medicare based amount is not available, “the 24 MRC is determined based on the lesser of: the health care professional or facility’s normal charge 25 for a similar service or supply; or the MRC Option I methodology based on the 80th percentile of 26

27 2 The Background is a brief summary of the allegations in the FAC. See Dkt. No. 63. Case No.: 5:20-cv-02255-EJD 1 billed charges.” Id. ¶ 69 (emphasis added). Thus, all claims at issue were required to be paid 2 using the MRC-1 methodology. Id. ¶ 70. 3 Plaintiffs received intensive outpatient program (“IOP”) services from Summit Estate for 4 behavioral health disorders, including for mental health and substance use disorders. Id. ¶¶ 54-55, 5 275, 282, 308. Plaintiffs submitted timely claims for their treatment to Cigna. Id. ¶ 57. Cigna 6 approved the claims for payment, but underpaid all of them. Id. ¶¶ 58, 79, 82-83. Plaintiffs used 7 their own funds and resources to pay the unpaid portion of their claims to their treatment 8 providers. Id. ¶ 59. 9 Plaintiffs allege that Cigna was required, but failed to pay each and every one of the claims 10 at issue at the usual, customary, and reasonable rate (“UCR”). Id. ¶¶ 60, 84. “That is, it was 11 required to pay an amount based on the competitive fees of similar MH/SUD treatment providers 12 in the same geographic area.” Id. ¶ 60. “UCR is a commonly accepted term in the healthcare 13 industry and means generally, the competitive rate charged by similar providers of the same 14 specialty in the same geographic area.” Id. ¶ 64. For the claims at issue, the UCR rate is “what 15 Cigna was required to reimburse as the ‘Maximum Reimbursable Charge’ (‘MRC’).” Id. ¶ 65. 16 Plaintiffs understood the UCR rate for MRC I policies to mean the same as or substantially similar 17 to what was published on Cigna’s website:

18 [A] data base compiled by FAIR Health, Inc. (an independent non- profit company) is used to determine the billed charges made by 19 health care professionals or facilities in the same geographic area for the same procedure codes using data. The maximum reimbursable 20 amount is then determined by applying a percentile (typically the 70th or 80th percentile) of billed charges, based upon the FAIR Health, 21 Inc. data. For example, if the plan sponsor has selected the 80th percentile, then any portion of a charge that is in excess of the 80th 22 percentile of charges billed for the particular service in the same relative geographic area (as determined using the FAIR Health, Inc. 23 data) will not be considered in determining reimbursement and the patient will be fully responsible for such excess. 24 25 Id. ¶¶ 66-67; see also ¶¶ 310, 340 (“[I]t was customary and understood by all parties that payment 26 according to the plan would default to either 1) the lesser of Summit Estate’s normal charge for a 27 Case No.: 5:20-cv-02255-EJD 1 similar service or supply; or 2) 80th percentile of the healthcare charges made by similar providers 2 in the same geographic area, i.e. the ‘Fair Health’ 80th percentile benchmark.”). For many years 3 and until about 2015, Cigna was legally required to use the “FAIR Health” database to calculate 4 UCR in its payment of claims. Id. ¶ 75. “The significant differences between the publicly 5 available FAIR Health estimates and actual payments provide compelling evidence that the 6 Plaintiffs’ claims were not paid based on the UCR.” Id. ¶ 76. 7 Instead of applying the MCR I methodology, Defendants used Viant’s methodology to 8 “fabricate a fraudulent UCR rate and withhold a substantial part of the payment owed for 9 Plaintiffs’ claims.” Id. ¶ 84. “Viant’s methodology operates by culling data from a ‘Outpatient 10 Standard Analytical File’ (‘SAF’).” Id. ¶ 185. An SAF is composed of data collected from 11 Medicare Part B providers for services rendered to Medicare beneficiaries by the Department of 12 Health and Human Services (DHHs) / Centers for Medicaid and Medicaid Services (CMS). Id. 13 This methodology produced rates that are a fraction of the FAIR Health benchmark. Id. ¶ 164.

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RJ v. Cigna Behavioral Health, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/rj-v-cigna-behavioral-health-inc-cand-2022.