UC Davis Medical Center v. The Chefs Warehouse, Inc. Employee Benefit Plan

CourtDistrict Court, E.D. California
DecidedAugust 26, 2024
Docket2:23-cv-00676
StatusUnknown

This text of UC Davis Medical Center v. The Chefs Warehouse, Inc. Employee Benefit Plan (UC Davis Medical Center v. The Chefs Warehouse, Inc. Employee Benefit Plan) is published on Counsel Stack Legal Research, covering District Court, E.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
UC Davis Medical Center v. The Chefs Warehouse, Inc. Employee Benefit Plan, (E.D. Cal. 2024).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 FOR THE EASTERN DISTRICT OF CALIFORNIA 10 11 The Regents of the University of California, a No. 2:23-cv-00676-KJM-CKD California Public Trust Corporation, on behalf 12 of the University of California, Davis Medical ORDER Center, 13 14 Plaintiff, 15 v. 16 The Chefs’ Warehouse, Inc. Employee Benefit Plan, et al., 17 Defendants. 18 19 20 Plaintiff, the Regents of the University of California, on behalf of the University of 21 California, Davis Medical Center (UC Davis Medical Center), alleges defendants, the Chefs’ 22 Warehouse, Inc. Employee Benefit Plan, Chefs’ Warehouse, Inc., and doe defendants wrongfully 23 deprived Patient A, the plan beneficiary, from benefits provided by the plan. Patient A assigned 24 her rights to the medical center, which now assert claims against the plan. The plan moves to 25 dismiss for failure to state a claim. The court grants the motion. 26 I. BACKGROUND 27 On or around August 3, 2021, Patient A received inpatient cancer surgery at the hospital 28 known as UC Davis Medical Center. First Am. Compl. (FAC) ¶ 11, ECF No. 26. The hospital 1 discharged her on August 7, 2021, and Patient A received chemotherapy, radiation and other 2 related services for several months thereafter. Id. ¶¶ 11–12. The hospital charged Patient A 3 $397,519.31 for the treatment of her obstetric-gynecologic (OB/GYN) cancer. Id. ¶¶ 13, 83. 4 Patient A participated in a self-insured group health plan, meaning the employer paid plan 5 benefits directly from a fund generated in part by contributions from both the employer and 6 employees. See id. ¶ 30; Plan Doc., FAC Ex. A at 2, ECF No. 26-1. The plan, formally titled 7 “The Chefs’ Warehouse, Inc. Employee Benefit Plan,” uses a network of individual physicians. 8 FAC ¶¶ 40–45; Plan Doc. at 15. However, it does not use a network of hospitals. FAC ¶ 40. For 9 example, Patient A’s primary attending physician is “in-network,” id. ¶ 85, but the one hospital 10 where that physician practices is not in the plan’s network, id. Individual physicians cannot 11 provide complete care and treatment for OB/GYN cancer. Id. ¶¶ 51, 83, 90. To receive treatment 12 for her cancer, Patient A needed hospital services. Id. ¶¶ 17–18, 86. However, the plan did not 13 include hospital facilities that could provide the care she needed, let alone any hospitals, in its 14 network. Id. ¶ 86. 15 The specific terms of the plan are detailed in the “Plan Document and Summary Plan 16 Description,” which is attached to the hospital’s complaint. See Plan Doc. According to this 17 document, benefits under the plan include 100 percent coverage of many services including 18 chemotherapy, radiation therapy, inpatient and outpatient hospital care and emergency services, 19 and other treatments after the deductible. See id. at 7–13. The deductible for individuals is 20 $2,700. Id. at 7. The plan also includes an individual out-of-pocket expense limit of $3,600, 21 which is “the most the covered person could pay in a year for covered services.” Id. (emphasis in 22 original). However, the plan excludes from the out-of-pocket expense limit “expenses in excess 23 of allowable claim limit.” Id. (emphasis in original). The plan defines the “allowable claim 24 limit” as “the charges for services and supplies, listed and included as covered expenses from a 25 facility or nonpreferred provider under the Plan, which are medically necessary for the care and 26 treatment of illness or injury, but only to the extent that such fees are within the allowable claim 27 limits.” Id. at 30 (emphases in original). For facilities, including hospitals, the allowable claim 28 limit is the greater of “(I) 112% of the facility’s most recent departmental cost ratio, reported to 1 the Centers for Medicare and Medicaid Services (“CMS”) and published in the American 2 Hospital Directory as the “Medicare Cost Report” (the “CMS Cost Ratio”), or (II) the Medicare 3 allowed amount for the services in the geographic area plus an additional 20%.” Id.; see also 4 FAC ¶¶ 68, 148. 5 In addition to the plan’s individual out-of-pocket expense limit, the Public Health Service 6 (PHS) Act, which was amended by the Patient Protection and Affordable Care Act (ACA), sets an 7 annual maximum out-of-pocket limitation for essential health benefits. See Patient Protection and 8 Affordable Care Act, Pub. L. No. 111-148, § 1201, 124 Stat 119, 161 (2010). Specifically, PHS 9 Act section 2707(b) provides: “A group health plan shall ensure that any annual cost-sharing 10 imposed under the plan does not exceed the limitations provided for under paragraph (1) of 11 section 18022(c) of this title.” 42 U.S.C. § 300gg-6(b). In other words, a health plan must ensure 12 a plan beneficiary’s out-of-pocket costs do not exceed the cost-sharing limitation; in 2021 the 13 maximum out-of-pocket limitation for individuals was $8,550. See FAC ¶¶ 224, 236. Section 14 18022(c)(3) of Title 42 of the United States Code, also known as ACA section 1302(c), in turn 15 defines “cost-sharing” to include “deductibles, coinsurance, copayments, or similar charges; and 16 [] any other expenditure required of an insured individual which is a qualified medical 17 expense . . . with respect to essential health benefits covered under the plan.” 42 U.S.C. 18 § 18022(c)(3)(A). Cost-sharing “does not include premiums, balance billing amounts for non- 19 network providers, or spending for non-covered services.” Id. § 18022(c)(3)(B). 20 In accordance with its terms, the plan paid about a fifth of the total hospital bill, 21 $74,512.84. FAC ¶¶ 13, 100–01. This has left Patient A responsible for the remaining 22 $323,006.47. The hospital alleges the plan employed a controversial “reference-based pricing” 23 model, which is when a plan sets a specific limit on how much it will pay for certain health 24 services. See id. ¶¶ 21–29, 53–81. As noted, the plan set reference points as the greater of “the 25 Medicare allowed amount plus an additional 20%; or, instead, based on an estimate of 112% of 26 what it would have cost for the hospital to provide the service in question[.]” Id. ¶ 100. The 27 hospital alleges it never agreed to be subject to this pricing methodology and no other hospital has 28 “ever agreed up-front to accept the Plan’s methodology as payment in full.” Id. ¶ 103. Here, the 1 plan used the reference price based on 112 percent of the hospital’s costs. Id. ¶ 101. Curiously, 2 the hospital does not allege what Patient A’s actual cost of care was or whether the plan paid less 3 than that amount. Cf. id. ¶¶ 104–05 (alleging “Medicare rates are widely recognized to pay less 4 than the cost of care” and hospitals “contract with major insurers at rates that are equivalent to 5 somewhere between 250% and 400% of Medicare”). 6 After exhausting all internal appeals with the plan’s administrators, the hospital brought 7 this action against the plan. See id. ¶¶ 71, 202–05, 222–23; Compl., ECF No. 1. The court 8 dismissed the initial complaint for failing to state a claim, but granted leave to amend. Prior 9 Order, ECF No. 25. The hospital filed an amended complaint and now alleges Patient A is 10 entitled to benefits above the maximum annual out-of-pocket limit. FAC ¶¶ 224, 236. Patient A 11 assigned her benefits to the hospital. Id. ¶¶ 9, 215–21, 228, 230. The hospital brings two nearly 12 identical claims under the Employee Retirement Income Security Act (ERISA): 1) Patient A is 13 entitled to benefits above the maximum annual out-of-pocket limitation under the terms of the 14 plan and in accordance with ERISA section 502(a)(1)(B) and 2) Patient A is entitled to those 15 same benefits under PHS Act section 2707(b)1 based on ERISA section 502(a)(1)(B). Id. ¶¶ 214– 16 37.

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UC Davis Medical Center v. The Chefs Warehouse, Inc. Employee Benefit Plan, Counsel Stack Legal Research, https://law.counselstack.com/opinion/uc-davis-medical-center-v-the-chefs-warehouse-inc-employee-benefit-plan-caed-2024.