S. v. Health Savings Account HSA Plan A119 of Inmoment

CourtDistrict Court, D. Utah
DecidedJanuary 29, 2021
Docket2:18-cv-00672
StatusUnknown

This text of S. v. Health Savings Account HSA Plan A119 of Inmoment (S. v. Health Savings Account HSA Plan A119 of Inmoment) is published on Counsel Stack Legal Research, covering District Court, D. Utah primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
S. v. Health Savings Account HSA Plan A119 of Inmoment, (D. Utah 2021).

Opinion

IN THE UNITED STATES DISTRICT COURT DISTRICT OF UTAH

BRIANNA S., MEMORANDUM DECISION AND ORDER GRANTING [52] Plaintiff, DEFENDANT’S MOTION FOR SUMMARY JUDGMENT AND v. DENYING [54] PLAINTIFF’S MOTION FOR SUMMARY JUDGMENT UNITEDHEALTHCARE, Case No. 2:18-cv-00672-DBB Defendant. District Judge David Barlow

Defendant UnitedHealthcare Insurance Company moved for summary judgment1 on all three causes of action in Plaintiff Brianna S.’s Complaint2 for relief under the Employee Retirement Income Security Act of 1974 (ERISA). Plaintiff opposed Defendant’s Motion for Summary Judgment3 and Defendant replied in support.4 Plaintiff also filed her own motion seeking summary judgment5 in her favor on all three of her causes of action. Defendant opposed Plaintiff’s Motion for Summary Judgment6 and Plaintiff replied in support.7

1 Defendant’s Motion for Summary Judgment, ECF No. 52, filed under seal December 10, 2019. 2 Amended Complaint, ECF No. 5, filed September 24, 2018. 3 Plaintiff’s Opposition to Defendant’s Motion for Summary Judgment, ECF No. 60, filed January 21, 2020. 4 Defendant’s Reply in Further Support of Motion for Summary Judgment, ECF No. 69, filed under seal February 4, 2020. 5 Plaintiff’s Motion for Summary Judgment and Memorandum in Support, ECF No. 54, filed December 10, 2020. 6 Defendant’s Opposition to Plaintiff’s Motion for Summary Judgment, ECF No. 63, filed under seal January 22, 2020. 7 Plaintiff’s Reply and Memorandum in Further Support of her Motion for Summary Judgment, ECF No. 67, filed February 4, 2020. Defendant also filed the material constituting the complete administrative record (Administrative Record)8 for the court’s review: the pertinent employee benefit plan, the Health Savings Account (HSA) Plan AII9 of InMoment employee welfare benefit plan (Plan) under which Plaintiff sought coverage for medical treatment, relevant medical records, correspondence,

the independent external review determination, and other documents which were considered during Plaintiff’s claim and appeal review process. The court has reviewed the complete briefing for both motions for summary judgment and the Administrative Record.9 Based on the facts provided in the Administrative Record, summary judgment for Defendant is appropriate and the court grants Defendant’s Motion for Summary Judgment in total. The court denies Plaintiff’s Motion for Summary Judgment. BACKGROUND Terms of the Plan and Discretionary Authority During the relevant period, Plaintiff was a beneficiary under the Plan that is governed by ERISA.10 The Plan benefits are funded by a group insurance policy issued and administered by Defendant.11 The Plan identifies Defendant as the designated claims fiduciary.12 The Plan also identifies Defendant and employer InMoment as joint Plan administrators.13 According to the

“Interpretation of Benefits” provision of the plan, benefits under the Plan “will be paid only if [United] decide[s] in [its] discretion that [the covered person is] entitled to them. [United] also

8 Administrative Record, ECF No. 53, filed under seal December 10, 2019. 9 The court notes that Plaintiff also filed a statement of subsequent authority. See Plaintiff’s Notice of Supplemental Authority, ECF No. 71, filed July 24, 2020. However, the court has reviewed that filing and has determined that the case offered therein, a nonbinding case from another district, has no bearing on the central, dispositive issues of this case. 10 Amended Complaint at 2, Administrative Record at 161. 11 Administrative Record at 1, 64. 12 Id. at 161. 13 Id. ha[s] discretion to determine eligibility for Benefits and to interpret the terms and conditions of the benefit plan.”14 The Plan also states that United may delegate its discretionary authority “to other persons or entities that provide services in regard to the administration of the Policy.”15 In turn, according to the Plan:

[T]he Plan Administrator and other Plan fiduciaries shall have discretionary authority to interpret the terms of the Plan and to determine eligibility for benefits in accordance with the terms of the Plan. Any interpretation or determination made pursuant to such discretionary authority shall be given deference and be legally binding on all parties and subject to review by a legal authority only to the extent the decision was arbitrary and capricious.16 As to matters pertaining to mental health and substance abuse disorder treatment, the Plan vests this discretionary authority in United Behavioral Health (UBH).17 Medical services will be not be covered under the Plan unless they are “Medically Necessary,” as that term is defined in the Plan.18 According to the Plan, “Medically Necessary” is defined as “health care services provided for the purpose of preventing, evaluating, diagnosing or treating a Sickness, Injury, Mental Illness, substance-related and addictive disorders, condition, disease or its symptoms, that are all of the following as decided by us or our designee . . . [i]n accordance with Generally Accepted Standards of Medical Practice.”19 “Generally Accepted Standards of Medical Practice” as established in the Plan means: [S]tandards that are based on credible scientific evidence published in peer- reviewed medical literature generally recognized by the relevant medical community, relying primarily on controlled clinical trials, or, if not available,

14 Id. at 94. 15 Id. 16 Id. at 161–162. 17 Id. at 48. 18 Id. at 99. 19 Id. at 104. observational studies from more than one institution that suggest a causal relationship between the service or treatment and health outcomes.20 And according to the Plan: If no credible scientific evidence is available, then standards that are based on Physician specialty society recommendations or professional standards of care may be considered. We reserve the right to consult expert opinion in determining whether health care services are Medically Necessary. The decision to apply Physician specialty society recommendations, the choice of expert and the determination of when to use any such expert opinion, shall be determined by us.21 Continuing as to the meaning and application of “Generally Accepted Standards of Medical Practice,” the Plan states: We develop and maintain clinical policies that describe the Generally Accepted Standards of Medical Practice scientific evidence, prevailing medical standards and clinical guidelines supporting our determinations regarding specific services. These clinical policies (as developed by us and revised from time to time), are available to Covered Persons on www.myuhc.com or by calling Customer Care at the telephone number on your ID card, and to Physicians and other health care professionals on UnitedHealthcareOnline.22 Coverage is provided in the Plan for Medically Necessary Mental Health Services, which “include those received on an inpatient or outpatient basis in a Hospital, an Alternate Facility or in a provider's office” and are “provided by or under the direction of a properly qualified behavioral health provider.23 As to these mental health services, the Plan defines “Residential Treatment” as “treatment in a facility which provides Mental Health Services or Substance Use Disorder Services treatment” and which meets certain requirements, including that the facility “provides a program of treatment under the active participation and direction of a Physician and approved by the Mental Health/Substance Use Disorder Designee.”24

20 Id. 21 Id. at 105 22 Id. 23 Id at 48. 24 Id. at 107.

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S. v. Health Savings Account HSA Plan A119 of Inmoment, Counsel Stack Legal Research, https://law.counselstack.com/opinion/s-v-health-savings-account-hsa-plan-a119-of-inmoment-utd-2021.