UNITED STATES OF AMERICA v. COMMUNITY HEALTH NETWORK, INC.

CourtDistrict Court, S.D. Indiana
DecidedApril 27, 2023
Docket1:14-cv-01215
StatusUnknown

This text of UNITED STATES OF AMERICA v. COMMUNITY HEALTH NETWORK, INC. (UNITED STATES OF AMERICA v. COMMUNITY HEALTH NETWORK, INC.) is published on Counsel Stack Legal Research, covering District Court, S.D. Indiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
UNITED STATES OF AMERICA v. COMMUNITY HEALTH NETWORK, INC., (S.D. Ind. 2023).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF INDIANA INDIANAPOLIS DIVISION

UNITED STATES OF AMERICA, ) STATE OF INDIANA, ) ) Plaintiffs, ) ) v. ) No. 1:14-cv-01215-RLY-MKK ) COMMUNITY HEALTH NETWORK, INC., ) et al., ) ) Defendants. ) ) ) THOMAS P. FISCHER, ) ) Relator. )

ORDER

This matter comes before the Court on the United States' Motion to Compel Defendant Community Health Network, Inc. to Revise and Supplement its Responses to Interrogatories 3-5 (First Set), Dkt. [500]. The motion was referred to the undersigned and, for the reasons that follow, is hereby GRANTED. I. Background A. United States' Complaint Relator, Thomas Fischer, filed a qui tam complaint on July 21, 2014, alleging that the Defendants had violated the False Claims Act and the Indiana False Claims and Whistleblower Protection Act. (Dkts. 1, 32). On August 7, 2019, the United States elected to intervene in part and declined to intervene in part. (Dkt. 86).1 The United States' Complaint in Intervention, against only Defendant Community Health Network, Inc. ("CHN"), was filed on January 6, 2020. (Dkt. 96). The United States contends that CHN knowingly submitted claims to Medicare that

were false because they resulted from violations of the federal physician self- referral law, commonly known as the Stark Law. (Id. at 1). It alleges that CHN violated the Stark Law by (1) submitting claims to Medicare for designated health services referred by certain specialists to whom Community Health paid salaries that exceeded fair market value, (id. at 16-18), and (2) submitting claims to Medicare for designated health services referred by physicians to whom CHN paid service line financial performance ("SLFP") bonuses that took into account the

volume or value of the physicians' referrals to CHN, (id. at 19). B. Discovery Dispute On April 9, 2021, the United States served its first set of interrogatories on CHN related to the second alleged violation. (Dkt. 363-1). After two years, too many meet and confers, half a dozen discovery conferences, and two different Court Orders requiring CHN to provide complete, narrative answers, (see Dkts. 364, 477),

the United States has moved to compel CHN to provide the answers this Court has already ordered it to provide, (Dkt. 500). At issue are CHN's answers to Interrogatory Nos. 3, 4, and 5. Interrogatory No. 3: "Identify every physician employed by CHN (or any other entity identified in your answer to Interrogatory No. 1) who received incentive compensation that was based in part on or

1 The State of Indiana declined to intervene on December 23, 2019. (Dkt. 94). included a service line financial performance bonus." (Dkt. 500-1 at 3). Interrogatory No. 4: "For each physician identified in your answer to Interrogatory No. 3, describe how the service line financial performance bonus was calculated or determined." (Id. at 5). Interrogatory No. 5: "For each physician identified in your answer to Interrogatory No. 3, describe the criteria for receipt of a service line financial performance bonus, including how the criteria were established." (Id. at 7). Initially, CHN objected to these three interrogatories (and related requests for production), claiming that they were "overly broad, unduly burdensome, not proportional to the needs of the case, and s[ought] information outside of the scope of the Complaint." (Dkt. 403-2).2 On September 21, 2021, the parties had a discovery conference with then-Magistrate Judge Pryor. After considering the parties' submissions and hearing further argument on the issue, Judge Pryor found Interrogatory Nos. 3 through 5 both relevant and proportional and concluded that CHN had not proven that any burden in responding to these requests would be undue. (Dkt. 235). She then ordered CHN to "immediately" begin production. (Id. at 2). CHN never objected to that order. At the October 28, 2021 status conference, Defendants had produced no documents, but represented that all discovery production in response to the United States' discovery requests would be completed on or before November 30, 2021. (Dkt. 246).

2 This Court's December 27, 2022 Entry on Defendant's Objection to Magistrate Judge's Minute Entry for May 13, 2022 Discovery Conference exhaustively explains the history related to the present discovery dispute. (Dkt. 477). The undersigned will largely reuse that summary, as the full picture is relevant for this opinion. On November 30, 2021, CHN produced nearly 26,000 documents which it said were responsive to the United States' RFPs on incentive compensation. (Dkt. 363-1 at 69). CHN also produced a spreadsheet in response to Interrogatory Nos. 3

through 5 identifying 119 physicians who received incentive compensation and were "eligible for a SLFP bonus pursuant to their employment agreements." (Id. (emphasis in original)). The spreadsheet, contrary to what a full and complete answer to Interrogatory No. 3 would look like, did not indicate whether the physicians had in fact received a SLFP bonus. Along with the spreadsheet came CHN's invocation of Rule 33(d), "referring the United States to the 25,767 documents . . . produced in response to [the RFPs]" that would contain CHN's

responses. (Id.). The United States believed CHN had improperly relied on Rule 33(d) in responding to the interrogatories and, after several uneventful meet and confers, sought the Magistrate Judge's intervention. In a discovery dispute statement, the United States noted that CHN's response did not (1) "identify even a single physician who actually received a SLFP bonus (Interrogatory No. 3)"; (2) "describe

how the SLFP bonuses were calculated or determined (Interrogatory No. 4)"; or (3) "provide the criteria for receipt of a SLFP bonus and explain how those criteria were established (Interrogatory No. 5)." (Dkt. 363-5 at 5 (emphasis in original)). Instead, the United States argued, CHN abused the Rule 33(d) option by pointing it to a mass of documents without "identify[ing] the particular documents responsive to each of the incentive compensation interrogatories" or even "certify[ing] . . . the responses to the . . . interrogatories are actually ascertainable from the documents produced." (Id. at 4, 9). In a letter to the Magistrate Judge, CHN explained its "payroll department

did not receive information about the various components that went into each physician's incentive compensation." (Id. at 93). So, while "it can determine from payroll records which physicians received incentive compensation for any given year," it does not "track[] or store[] in a centralized location" information related to SLFP bonuses specifically. (Id. (emphasis in original)). Prior to 2018, those bonuses were "calculated by each individual service line before compensation information was sent to CHN's payroll department." (Id.). The metrics for SLFP bonuses also

"varied by service line . . . and were often revised on an annual basis." (Id.). This meant, CHN maintained, that it was " extraordinarily difficult to determine which physicians received incentive compensation that had a SLFP component, what metrics were used for any SLFP component and who was involved in making the decision." (Id.). That information, "to the extent it exists," "could only be derived from reviewing documents;" namely, "the [26,000] documents produced by CHN to

the United States on November 30, 2021." (Id. at 94). On February 1, 2022, the parties presented their arguments to the Magistrate Judge during a discovery conference. During that conference, the Magistrate Judge noted she was "not confident that at this juncture CHN ha[d] met the requirements of Rule 33." (Dkt. 328 at 41).

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UNITED STATES OF AMERICA v. COMMUNITY HEALTH NETWORK, INC., Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-of-america-v-community-health-network-inc-insd-2023.