Sobertec LLC v. UnitedHealth Group Inc.

CourtDistrict Court, C.D. California
DecidedSeptember 5, 2019
Docket8:19-cv-01206
StatusUnknown

This text of Sobertec LLC v. UnitedHealth Group Inc. (Sobertec LLC v. UnitedHealth Group Inc.) is published on Counsel Stack Legal Research, covering District Court, C.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Sobertec LLC v. UnitedHealth Group Inc., (C.D. Cal. 2019).

Opinion

CUENNTITREADL S DTIASTTERSIC DTI SOTFR CICATL ICFOOURRNTIA CIVIL MINUTES - GENERAL Case No. SACV 19-1206 JVS (MRWx) Date September 5, 2019 Title Sobertec LLC v. UnitedHealth Group, Inc., et al.

Present: The James V. Selna, U.S. District Court Judge Honorable Lisa Bredahl Not Present Deputy Clerk Court Reporter Attorneys Present for Plaintiffs: Attorneys Present for Defendants: Not Present Not Present Proceedings: [IN CHAMBERS] Order Regarding Motion to Remand Plaintiffs Sobertec LLC (“Sobertec”) and Beachside Recovery LLC (“Beachside”) (together— “Plaintiffs”) filed a motion to remand. (Mot., Dkt. No. 21.) Defendants UnitedHealth Group Incorporated (“UHGI”), United HealthCare Services, Inc. (“UHSI”), United Healthcare Insurance Company (“UHIC”), United Behavioral Health (“UBH”), UnitedHealthcare Service LLC (together— “United”), Optuminsight, Inc., and Optum Services, Inc. (all together— “Defendants”) opposed the motion. (Opp’n, Dkt. No. 28.) Plaintiffs replied. (Reply, Dkt. No. 30.) For the following reasons, the Court grants the motion to remand. I. BACKGROUND Plaintiffs allege the following. Plaintiffs operate addiction treatment facilities in Orange County, California that are licensed and certified to provide detox, residential inpatient, and intensive outpatient services. (Complaint, Dkt. No. 1-1, Ex. A ¶¶ 53, 54.) UHIC and UHSLLC provide or manage health insurance coverage policies at issue with the other defendants. (Id. ¶ 74.) UBH and Optum are responsible for reviewing, authorizing, processing, and paying claims submitted by Plaintiffs for beneficiaries of UHSI, UHIC, and/or UHSLLC. (Id. ¶ 75.) UBH and Optum are responsible for reviewing and responding to provider appeals and performing so-called audits and investigations of mental health services providers, including Plaintiffs. (Id.) Plaintiffs have been providing addiction treatment services to Defendants’ insureds as out-of- CUENNTITREADL S DTIASTTERSIC DTI SOTFR CICATL ICFOOURRNTIA CIVIL MINUTES - GENERAL Case No. SACV 19-1206 JVS (MRWx) Date September 5, 2019 Title Sobertec LLC v. UnitedHealth Group, Inc., et al.

Although no in-network agreement applied, Defendants’ insureds sought out Plaintiffs as their providers to render care, and Plaintiffs therefore regularly treated Defendants’ insureds and promptly submitted bills to Defendants for payment at Plaintiffs’ reasonable and customary rates for those out-of-network services. (Id. ¶ 80.) Consistent with industry norms and custom, when approached by United’s insureds, Plaintiffs first called Defendants to verify their members’ benefits and confirm those members’ eligibility, and obtain basic information about their coverage for the purposes of receiving mental healthcare, such as effective coverage date, deductibles, copays, out-of-pocket maximums, and the plan’s rate structure for out-of-network services. (Id. ¶ 81.) During each of these verification calls, Defendants gave Plaintiffs a unique reference number that could be used to identify the specific call. (Id.) Before Plaintiffs provided any substantial treatment to a particular member, Plaintiffs would call Defendants again for an initial “pre-authorization” or “pre-certification” to provide care to that member. (Id. ¶ 82.) During this pre-authorization process, Defendants would typically request information about Plaintiffs’ facilities to confirm that Plaintiffs are eligible providers. (Id.) Then, Defendants and Plaintiffs would typically discuss the particulars of the member’s clinical presentation, needs, and the specific treatments that Plaintiffs identified as necessary for that member. (Id.) In so doing, Plaintiffs would ordinarily provide information obtained from the member, such as the member’s mental status, vital signs, current medications, medical history, and other relevant details as requested in order to determine whether the proposed course of treatment was appropriate. (Id.) Based on this clinical discussion, Defendants would then “authorize” Plaintiffs to provide the specific proposed care. (Id.) For any further authorizations, Plaintiffs and Defendants would engage in detailed, further clinical discussions about the member’s progress, status, and need for further treatment. (Id. ¶ 83.) Plaintiffs relied on these benefits verifications, authorizations and related representations from Defendants, and this course of dealing generally, consistent with industry custom and practice, in agreeing to provide care to Defendants’ insureds. (Id. ¶ 84.) Prior to 2016, Plaintiffs and Defendants generally conducted business successfully and efficiently, and without significant incident. (Id. ¶ 85.) Defendants would typically CUENNTITREADL S DTIASTTERSIC DTI SOTFR CICATL ICFOOURRNTIA CIVIL MINUTES - GENERAL Case No. SACV 19-1206 JVS (MRWx) Date September 5, 2019 Title Sobertec LLC v. UnitedHealth Group, Inc., et al.

paid Plaintiffs in a manner consistent with the information that Defendants conveyed during the process of verifying the members’ benefits and generally would not request the submission of medical records with the claims. (Id.) Defendants knew that Plaintiffs were treating, and would continue to treat, their insureds. (Id. ¶ 114.) Both Defendants and Plaintiffs knew or had reason to know that the other party would interpret their ongoing relationship and performance as creating a contract under which Defendants agreed to pay Plaintiffs for Plaintiffs’ out-of-network services rendered to Defendants’ insureds at Plaintiffs’ reasonable rate for such services. (Id.) Plaintiffs have performed all duties required under this implied-in-fact contract. (Id. ¶ 115.) Defendants knew that Plaintiffs’ services were not being provided to Defendants’ insureds free of charge. (Id. ¶ 118.) When Defendants’ insureds and enrollees sought addiction treatment from Plaintiffs, Defendants confirmed to Plaintiffs that the treatment was authorized and would be covered. (Id. ¶ 119.) Defendants specifically requested and authorized Plaintiffs’ services or otherwise promised, consented pledged, agreed, and committed to pay the reasonable cost of Plaintiffs’ services rendered to Defendants’ insureds. (Id.) It was only after Plaintiffs rendered the treatment that Defendants refused to compensate Plaintiffs for these services. (Id. ¶ 120.) Defendants also represented to Plaintiffs that their claims and their facilities were under a valid “audit” and that, as a result, Plaintiffs were obligated to submit paperwork and other information, including extensive medical records, which Defendants represented would be received, reviewed, and used to process the claims, satisfy the audit if an 85% “passing rate” was achieved, and that Plaintiffs’ compliance and diligent response to such requests would ultimately result in Plaintiffs’ removal from the audit and “pre-payment” review. (Id. ¶ 131.) As a result of Defendants’ representations concerning coverage and payment and the validity of Defendants’ audit and claim review process, Plaintiffs continued rendering services to Defendants’ insureds. (Id. ¶ 134.) Plaintiffs provided services to Defendants’ insureds at great cost and have not received payment from Defendants for those services. (Id. ¶ 135.) Defendants had a duty to fairly and competently receive, review, and process Plaintiffs’ claims and supporting information submitted in connection with those claims. (Id. ¶ 146.) Defendants, however, have continually and grossly mishandled Plaintiffs’ CUENNTITREADL S DTIASTTERSIC DTI SOTFR CICATL ICFOOURRNTIA CIVIL MINUTES - GENERAL Case No. SACV 19-1206 JVS (MRWx) Date September 5, 2019 Title Sobertec LLC v. UnitedHealth Group, Inc., et al.

On May 14, 2019, Plaintiffs brought suit in California state court against Defendants alleging claims for (1) breach of implied-in-fact contract; (2) quantum meruit; (3) promissory estoppel; (4) fraud and deceit; (5) negligent misrepresentation; (6) negligence; and (7) unfair competition.

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Bluebook (online)
Sobertec LLC v. UnitedHealth Group Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/sobertec-llc-v-unitedhealth-group-inc-cacd-2019.