United States v. BRIGHTON MARINE INC

CourtDistrict Court, D. Maine
DecidedJune 2, 2025
Docket2:16-cv-00447
StatusUnknown

This text of United States v. BRIGHTON MARINE INC (United States v. BRIGHTON MARINE INC) is published on Counsel Stack Legal Research, covering District Court, D. Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. BRIGHTON MARINE INC, (D. Me. 2025).

Opinion

UNITED STATES DISTRICT COURT

DISTRICT OF MAINE

UNITED STATES OF AMERICA ) ex rel. JANE ROLLINSON and ) DANIEL GREGORIE, ) ) Plaintiff ) ) v. ) No. 2:16-cv-00447-LEW ) BRIGHTON MARINE, INC., ) CHRISTUS HEALTH, THE JOHNS ) HOPKINS MEDICAL SERVICES ) CORPORATION, MARTIN’S POINT ) HEALTH CARE, INC., PACMED ) CLINICS, SAINT VINCENTS ) CATHOLIC MEDICAL CENTERS ) OF NEW YORK, and US FAMILY ) HEALTH PLAN ALLIANCE, LLC ) ) Defendants )

ORDER ON MOTION TO DISMISS

In this action, the United States of America seeks to recover from the Defendants, a collection of healthcare providers, alleged overpayments made as the result of actuarial and computational errors on the part of a Department of Defense contractor. The matter is before the Court on the Defendants’ Motion to Dismiss (ECF No. 139). BACKGROUND AND CLAIMS In its review of a motion to dismiss, a court accepts as true all of the plaintiff’s well- pleaded factual allegations, indulges reasonable inferences that arise from them, and views the resulting picture in the light most favorable to the plaintiff’s cause. Guilfoile v. Shields, 913 F.3d 178, 186 (1st Cir. 2019). The following background statement observes these requirements.

The Department of Defense provides healthcare coverage to military families through various programs. One such program is the Uniformed Services Family Health Plan (USFHP). The Department of Defense delivers the healthcare services promised under the Plan through contracts with private providers. Each of the Defendants in this case is or was a Plan provider. Under governing law and as provided in the contracts between the Department and

the Defendants, it is unlawful for the Defendants to receive total reimbursements in excess of what the Department would otherwise pay if it delivered the Plan’s benefits by means of another program, such as TRICARE or Medicare.1 The parties agreed2 to calculate Plan reimbursement rates by means of a capitation payment, meaning a set amount for each enrolled beneficiary. Determination of the proper

capitation amount is a function of a computational process that relies on certain actuarial data and methodologies and the computational inputs vary according to the age of the beneficiary and the regional market. Between 2008 and 2012, the Department’s actuarial

1 See 110 Stat. 2422, § 726(b):

(b) LIMITATION ON TOTAL PAYMENTS.—Total capitation payments for health care services to a designated provider shall not exceed an amount equal to the cost that would have been incurred by the Government if the enrollees had received such health care services through a military treatment facility, the TRICARE program, or the Medicare program, as the case may be.

2 For its part, the Department of Defense relied on the services of an agent to oversee the Plan. That agent was known as the TRICARE Management Activity or TMA. In turn, the TMA relied on an actuarial service provider to represent its interest in connection with agreed upon actuarial approaches to rate setting under the Program. agent, Kennell & Associates, used the wrong actuarial data sets and methodologies when calculating capitation rates, producing rates in excess of what should have been produced

for beneficiaries age 65 and older. As a result, during this time, Defendants experienced and were aware of unusually high profit margins from their delivery of services under the Plan. In 2012, while negotiating rates for a new annual contract period, the Defendants learned that the Plan was so profitable due to Kennell’s actuarial errors in connection with capitation rates for beneficiaries aged 65 and older. Instead of informing the Department

of the overpayments, the Defendants allegedly met and collectively decided that they would modify their approach to negotiating capitation rates by advocating the use of a different computational methodology that would avoid tipping off the Department that the Defendants had received significant overpayments in the preceding years. This new approach produced a prolonged negotiation period, during which the Defendants accepted

an extension of the last, erroneous capitation reimbursement rate without informing the Department of the ongoing overpayments. The Defendants’ approach to the negotiation process was successful in terms of avoiding disclosure of the historic overpayments.3 During the negotiations, the Department expressed the understanding that, to its knowledge, there had been no significant actuarial validity issues in prior years, making

this statement in the context of a list of understandings. In a responsive letter, sent after

3 Kennell also learned of its errors and like Defendants did not notify the Department. According to the Intervenor Complaint’s allegations, Kennell & Associates has since entered into a settlement agreement with the Department “in an amount that, according to a qualified expert, is likely the maximum Kennell has the ability to pay.” Compl. ¶ 290. review by all of the Defendants, the Defendants crafted an obfuscatory responsive comment, effectively intentionally continuing to buffalo the Department to avoid the

disclosure of past overpayments. Certain of the Defendants, namely Martin’s Point and Christus, continued to advocate for a continuation of the earlier methodology, despite knowing that it would yield unsound and unjustified overpayments. Martin’s Point went so far as to argue, falsely, that the old rate should continue because it would assure that the capitation rate would be the product of an actuarially sound methodology. Christus made similarly misleading

statements in its bid to maintain the prior approach to capitation calculations. Throughout the 2012 negotiation process, the Defendants realized from communications made by the Department’s representative, the TRICARE Management Activity, that the Department continued to be unaware of the past errors and that Kennell & Associates had not provided any notice of their errors. Had the Department learned of

the errors, it would have discontinued all reimbursement based on erroneous capitation rates and would have sought to recover the “hundreds of millions” of dollars in overpayments. Intervenor Compl. ¶ 289. In 2016, following the filing of the relators’ qui tam complaint, the Department first learned of the overpayments.

In its Intervenor Complaint, the United States alleges that the errors in the capitation calculations caused the Department’s payments to the Defendants to exceed the statutory limit and to violate the actuarial soundness requirement and the health status adjustment comparison requirement of the contracts. FCA Claims In Count I of the Intervenor Complaint (ECF No. 88), the United States cites 31

U.S.C. § 3729(a)(1)(A) of the False Claims Act (FCA) and seeks damages for the Defendants’ knowing presentation of false claims after June 11, 2012. In Count II, the United States cites 31 U.S.C. § 3729(a)(1)(B) of the FCA and seeks damages for the Defendants’ knowing use of false records and/or statements in support of claims for payment, in connection with claims made after June 11, 2012. The United States itemizes the presentation dates for specific records and statements.

In Count III, the United States cites 31 U.S.C. § 3729(a)(1)(G) and seeks damages for “reverse false claims” consisting of knowingly making or using false records or statements to avoid an obligation to pay money back to the United States that Defendants were not entitled to and should never have received. In Count IV, the United States cites 31 U.S.C.

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