Trustees of IBEW and Arizona Chapter NECA Health and Welfare Trust Fund v. CIGNA Health and Life Insurance Company

CourtDistrict Court, D. Arizona
DecidedAugust 2, 2021
Docket2:20-cv-01260
StatusUnknown

This text of Trustees of IBEW and Arizona Chapter NECA Health and Welfare Trust Fund v. CIGNA Health and Life Insurance Company (Trustees of IBEW and Arizona Chapter NECA Health and Welfare Trust Fund v. CIGNA Health and Life Insurance Company) is published on Counsel Stack Legal Research, covering District Court, D. Arizona primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Trustees of IBEW and Arizona Chapter NECA Health and Welfare Trust Fund v. CIGNA Health and Life Insurance Company, (D. Ariz. 2021).

Opinion

1 WO 2 3 4 5 6 IN THE UNITED STATES DISTRICT COURT 7 FOR THE DISTRICT OF ARIZONA

9 Local 640 Trustees of IBEW and Arizona No. CV-20-01260-PHX-MTL Chapter NECA Health and Welfare Trust 10 Fund, ORDER

11 Plaintiff,

12 v.

13 CIGNA Health and Life Insurance Company, 14 Defendant. 15 16 The Board of Trustees of the IBEW Local No. 640 and Arizona Chapter NECA 17 Health and Welfare Trust Fund (the “Board” or the “Fund’s Trustees”) brings this action 18 as a fiduciary for a welfare benefit plan (the “Plan”). (Doc. 1.) Defendant Cigna Health and 19 Life Insurance Company (“Cigna”) has moved to dismiss this case and compel arbitration. 20 (Doc. 25.) Cigna’s motion is fully briefed. (Docs. 25, 28, 29.) For the reasons given below, 21 the Court will grant the motion to compel arbitration and dismiss this case. 22 I. BACKGROUND 23 The International Brotherhood of Electrical Workers, Local No. 640 and the 24 Arizona Chapter of the National Electrical Contractors Association established the IBEW 25 Local No. 640 and Arizona Chapter NECA Health and Welfare Trust Fund (the “Fund”). 26 (Doc. 1 ¶ 2.) The Fund allows employers and unions who are parties to collective 27 bargaining agreements to pool their resources and share the costs of running welfare benefit 28 plans. (Id. ¶ 3.) The Fund’s Trustees adopted the Plan, which is an employee welfare 1 benefit plan under § 3(1) of the Employee Retirement Income Security Act of 1974 2 (“ERISA”). (Id. ¶¶ 4–5.) 3 Rather than purchase insurance coverage, the Fund’s Trustees opted to self-fund the 4 Plan. (Id. ¶ 8.) Accordingly, employers, employees, and retirees contribute to the Fund, 5 and that money is then used to pay claims of Plan participants and beneficiaries. (Id. ¶¶ 25– 6 26.) The Board, “acting for the Fund as Plan sponsor,” executed an Administrative Services 7 Only Agreement (“ASO Agreement” or “Agreement”) with Cigna, which is one of the 8 largest health service companies in the country. (Id. ¶¶ 12, 39; Doc. 26-1 at 4.) Under the 9 terms of the Agreement, Cigna provided claims administration services to the Plan. (Doc. 1 10 ¶ 23; Doc. 26-1, Ex. A.) Consistent with the Agreement’s terms, Cigna received and 11 reviewed claims for Plan benefits, determined whether benefits were payable, and if so, 12 disbursed payments to healthcare providers using money supplied by the Fund. (Doc. 1 13 ¶ 33.) In exchange for its services, Cigna received compensation from the Plan. (Id. ¶¶ 28, 14 32.) Because the ASO Agreement grants Cigna the authority to control the Plan’s bank 15 account, Cigna paid itself the amounts the Plan allegedly owed. (Id.) 16 Among the terms in the Agreement are mandatory dispute resolution procedures. 17 (Doc. 26-1 at 9–10.) The procedures require “any dispute between the Parties arising from 18 or relating to the performance or interpretation of [the ASO] Agreement” to “first be 19 referred to an executive level employee of each Party who shall meet and confer with 20 his/her counterpart to attempt to resolve the dispute.” (Id. at 9.) If the dispute is not resolved 21 within 35 days of the request for executive review, “the disputing Party shall initiate 22 mediation.” (Id. at 10.) If the dispute remains unresolved, it “shall be settled by binding 23 arbitration.” (Id.) The term “Parties,” as used in the Agreement, “refers to [the] Fund and 24 CHLIC [i.e., Cigna], each a ‘Party’ and collectively, the ‘Parties.’” (Id. at 4.) 25 In October 2019, counsel for the Fund and the Fund’s Trustees provided Cigna 26 written notice of a dispute and requested executive review under the terms of the ASO 27 Agreement. (Doc. 26-1, Ex. C.) The Fund alleged that Cigna had breached its fiduciary 28 duties under ERISA, breached the ASO Agreement, and engaged in overpayment and self- 1 dealing. (Id. at 11–12.) To establish Cigna owed fiduciary duties under ERISA, the notice 2 explained: 3 The Agreement expressly empowers Cigna with each individually sufficient discretionary power to establish 4 ERISA fiduciary status. Foremost, Cigna has authority over 5 the Fund’s bank account, which is funded with ERISA- regulated monies deposited to pay the health expenses and the 6 administrative costs of the Fund’s enrollees. Additionally, the 7 Agreement stipulates Cigna has the authority to “receive and review claims for Plan Benefits,” “determine the Plan 8 Benefits, if any, payable for such claims,” and “disburse 9 payments of Plan Benefits to claimants.” In sum, the Agreement grants Cigna both requisite discretionary powers 10 necessary to find that Cigna is, as a claims administrator for a 11 self-funded plan, an ERISA fiduciary. Cigna has the ability to determine claims and pay claims. Based on this clear 12 reasoning, there can be no dispute that Cigna is an ERISA fiduciary to the Fund. 13 14 (Id. at 11 (footnote omitted) (second emphasis added).) The notice further alleged that 15 Cigna had “pa[id] unreasonable or unnecessary fees,” used “inflated and arbitrary billed 16 charges in the calculation of its fees,” and “pa[id] itself fees on claims that the Fund ha[d] 17 already been billed for and [were] not supported by the Agreement.” (Id. at 12–13.) 18 Additionally, the Fund noted that “Cigna’s Cost Containment Fees [had] increased from 19 roughly $34.50 [per employee per month (“PEPM”)] in 2016, to $75 PEPM for 2017, to 20 $112 PEPM for 2018 and to $122 PEPM for the first quarter of 2019” and argued Cigna 21 “masked” those fees “as a claims expense.” (Id. at 13–14.) In the Fund’s view, Cigna’s 22 actions “exacerbate[d] the breach and demonstrate[d] a willful disregard of Cigna’s duty 23 as a Plan fiduciary.” (Id. at 14.) 24 Cigna responded to the notice, and the Fund then sent Cigna a follow-up letter. 25 (Doc. 27, Exs. D, E.) In its letter, the Fund maintained that “Cigna had a duty, as a fiduciary 26 of the fund, to bring [certain] extreme fees to the attention of the trustees” and reasserted 27 that “Cigna has breached its fiduciary duty to the Fund and violated the terms of the ASO 28 Agreement.” (Id., Ex. E (emphasis added).) “Given the nature of [the] dispute, the amount 1 at issue, and the parties’ stated positions,” the Fund believed the dispute would not likely 2 be resolved by executive review, and thus the Fund “propose[d] that the parties agree to 3 move directly to the required mediation.” (Id.) 4 Instead of engaging in mediation, the Fund’s Trustees brought this lawsuit. In its 5 Complaint, the Board, “as fiduciary of its welfare benefit Plan,” asserts claims for breach 6 of fiduciary duty and prohibited transactions under ERISA. (Doc. 1.) The Complaint 7 alleges that Cigna “charged excessive fees to the Plan,” including fees for “a so-called ‘cost 8 containment service’” and “[h]idden [f]ees on in-network claims.” (Id. ¶¶ 60, 61, 78.) The 9 Board alleges that Cigna “processed grossly inflated healthcare claims from [non- 10 participating providers], and then used those inflated claims to calculate the amount of 11 [h]idden [f]ees to pay itself.” (Id. ¶ 66.) The Complaint also alleges that “Cigna’s fees for 12 its so-called ‘cost containment program’ have increased from roughly $34.50 per member, 13 per month (“PMPM”) in 2016, to $75 PMPM for 2017, to $112 PMPM for the first quarter 14 of 2019.” (Id. ¶ 124.) “These fees,” says the Board, “are many, many times the market rate 15 for out-of-network claims administration, violate Plan terms, and are indefensible under 16 any circumstance.” (Id. ¶ 125.) 17 Relying on the ASO Agreement’s arbitration clause, Cigna moves to compel 18 arbitration and dismiss this case. (Doc. 25.) The motion is ripe for ruling. (Docs. 25, 28, 19 29.) The Court ordered supplemental briefing on the Supreme Court’s decision in GE 20 Energy Power Conversion France SAS, Corp. v. Outokumpu Stainless USA, LLC, 140 S. 21 Ct. 1637 (2020), which the parties timely submitted. (Docs. 37, 38.) The Court now rules. 22 II.

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Trustees of IBEW and Arizona Chapter NECA Health and Welfare Trust Fund v. CIGNA Health and Life Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/trustees-of-ibew-and-arizona-chapter-neca-health-and-welfare-trust-fund-v-azd-2021.