UnitedHealthcare Services, Inc., United Healthcare Insurance Co., and UMR, Inc. v. Team Health Holdings, Inc., Ameriteam Services, LLC, and HCFS Health Care Financial Services, Inc.

CourtDistrict Court, E.D. Tennessee
DecidedOctober 24, 2025
Docket3:21-cv-00364
StatusUnknown

This text of UnitedHealthcare Services, Inc., United Healthcare Insurance Co., and UMR, Inc. v. Team Health Holdings, Inc., Ameriteam Services, LLC, and HCFS Health Care Financial Services, Inc. (UnitedHealthcare Services, Inc., United Healthcare Insurance Co., and UMR, Inc. v. Team Health Holdings, Inc., Ameriteam Services, LLC, and HCFS Health Care Financial Services, Inc.) is published on Counsel Stack Legal Research, covering District Court, E.D. Tennessee primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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UnitedHealthcare Services, Inc., United Healthcare Insurance Co., and UMR, Inc. v. Team Health Holdings, Inc., Ameriteam Services, LLC, and HCFS Health Care Financial Services, Inc., (E.D. Tenn. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TENNESSEE AT KNOXVILLE

UNITEDHEALTHCARE SERVICES, INC., ) UNITED HEALTHCARE INSURANCE CO., ) and UMR, INC., ) ) Plaintiffs, ) ) v. ) No. 3:21-CV-364-DCLC-DCP ) TEAM HEALTH HOLDINGS, INC., ) AMERITEAM SERVICES, LLC, and ) HCFS HEALTH CARE FINANCIAL ) SERVICES, INC., ) ) Defendants. )

MEMORANDUM AND ORDER This case is before the undersigned pursuant to 28 U.S.C. § 636, the Rules of this Court, and Standing Order 13-02. Now before the Court is Plaintiffs’ Motion to Compel Discovery [Doc. 164]. Defendants responded in opposition to the motion [Doc. 170], and Plaintiffs filed a reply [Doc. 171]. The motion is ripe for adjudication. See E.D. Tenn. L.R. 7.1(a). For the reasons set forth below, the Court GRANTS IN PART AND DENIES IN PART the motion [Doc. 164]. I. BACKGROUND On October 21, 2021, Plaintiffs filed the Complaint [Doc. 1]. “[Plaintiffs] provide health insurance or claim administration services under a variety of plans and policies [Id. ¶ 25]. They explain that this case involves “payments made from . . . Plaintiffs’ fully insured and self-funded plans” [Id.]. “Plaintiffs both fund and administer their fully insured plans[,]” and “pay claims submitted to these plans out of their own assets” [Id. ¶ 26]. With respect to “Plaintiffs’ self-funded plans, or Administrative Services Only (‘ASO’) plans[,]” these “are funded by contributions from their respective sponsor employers and member employees” [Id. ¶ 27]. Plaintiffs state that they “provide claim administration services for such plans pursuant to Administrative Services Agreements (‘ASAs’), which identify the rights and obligations of . . . [Plaintiffs] and the plan sponsors” [Id.]. “[T]he ASAs give . . . Plaintiffs the exclusive discretion and authority to monitor and pursue overpayments of plans funds” [Id. ¶ 29].

According to the Complaint, “Plaintiffs process (or ‘adjudicate’) and pay approximately one million claims every day” [Id. ¶ 32]. Given that volume, Plaintiffs submit that their employees cannot review every claim they receive and that providers and billing companies generally do not submit medical records with insurance claims to Plaintiffs [Id. ¶¶ 32–33]. Plaintiffs’ adjudication process is automated, meaning that they “rely on providers to supply truthful and accurate information with insurance claims, and require providers to attest to the accuracy of the claims they submit” [Id. ¶ 34]. Plaintiffs claim that Defendants “operate[] one of the largest emergency room staffing and billing companies in the United States” and that they “affiliate[] with or acquire[] medical groups

across the country” [Id. ¶¶ 2–3]. Plaintiffs state that “[t]hese medical groups have contracts with hospitals or hospital systems under which the medical groups staff hospital emergency departments” [Id. ¶ 3]. Plaintiffs claim, however, that “[Defendants] handle everything related to coding and billing of claims from [their] centralized billing centers” [Id.]. Plaintiffs contend that “[Defendants] submit[] claims using the standard CM-1500 claim form or its electronic equivalent” [Id. ¶ 36]. With respect to the claim forms, Plaintiffs state there are “[c]ertain fields . . . that are particularity important to the amount . . . Plaintiffs pay on claims” [Id. ¶ 37]. Plaintiffs submit that “CPT codes are among the most important information included in a claim[,]” explaining that they “are standardized codes that denote the type and degree of care rendered to a patient” [Id. ¶ 38]. Plaintiffs further allege that these codes “are the principal way in which providers convey to insurers and claims administrators the services for which they seek payment” [Id.]. Also, Plaintiffs state, “The type and degree of care indicated by the CPT code(s) included in a claim is a primary determinate of what the . . . Plaintiffs will pay on the claim” [Id. ¶ 39]. According to Plaintiffs, “[Defendants] block[] attempts by insurers and claims

administrators to contract directly with [their] affiliated medical-groups, and demand[] independence from hospitals within which [they] operate[] in [their] dealings with insurers and claims administrators” [Id. ¶ 48]. They state that recently, “[Defendants have] gained notoriety . . . for [their] aggressive pursuit of profit at the expense of patient and insurers alike” and that “[p]rivate equity firms generally, and Blackstone specifically, apply significant pressure to the companies they acquire (such as [Defendants]) to maximize near-termprofits” [Id. ¶¶ 50–51]. Plaintiffs allege that “[Defendants’] own compensation structure amplifies this incentive” [Id. ¶ 52]. Plaintiffs state that “[t]his lawsuit principally concerns a form of insurance fraud called

‘upcoding’” [Id. ¶ 55]. They allege that “[u]pcoding occurs when a provider submits a claim to an insurer or claims administrator utilizing an inaccurate billing code in order to obtain higher payment” and that “[t]he provider uses the billing code to deceive the insurer or claims administrator into overpaying by misrepresenting the type or degree of services rendered” [Id. ¶ 56]. Plaintiffs contend that “[Defendants] have systematically upcoded claims for emergency room services” [Id. ¶ 58]. Plaintiffs state that “providers generally bill emergency room services to insurers using consecutively numbered CPT codes from 99281 to 99285” and that “[h]igher numbers indicate more extensive and complex treatment billed at higher rates” [Id. ¶ 59]. “CPT codes 99285 and 99284 denote treatment of especially serious issues, typically requiring the physician’s immediate, sustained, and undivided attention” [Id. ¶ 61]. The higher “CPT code 99285 is reserved for relatively rare cases in which the patient is at imminent risk of death or loss of physiological function[,]” and “CPT Code 99284 denotes emergency care for particularly severe and complex but non-life threatening medical issues” [Id. ¶¶ 62, 64]. Plaintiffs allege that they began reviewing Defendants’ conduct in light of “allegations that

[Defendants] engaged in abusive billing practices” [Id. ¶ 67]. Plaintiffs focused their review on claims utilizing CPT Codes 99284–99285 [Id.]. After finding that Defendants were using CPT Code 99285 at a rate far higher than other providers, Plaintiffs requested and received medical records, which Plaintiffs allege did not support the CPT Code 99285 [Id. ¶¶ 68–69].1 Plaintiffs claim that “[Defendants] deliberately upcoded claims utilizing CPT codes 99285 and 99284 . . . in order to deceive . . . Plaintiffs into overpaying for emergency room services and to reap windfall profits at the . . . Plaintiffs’ and their customers’ and members’ expense” [Id. ¶ 88]. Plaintiffs state that they were damaged by Defendants’ upcoding, explaining that it “is a particularly insidious form of fraud that is difficult to uncover and resource-intensive to

investigate” and that here, “the number of affiliates through which [Defendants have] carried out [their] scheme, as well as [their] failure to disclose the identities of all of [their] affiliates, further obscured [their] systematic upcoding” [Id. ¶ 104]. In addition, Plaintiffs assert that they have been damaged by Defendants “extravagantly high bill[ing] charges” [Id. ¶ 111]. They state that Defendants also file litigation against patients “[w]hen insurers have declined to pay” and that they conceal charity care from patients, which “‘is a form of financial assistance for low-income patients’” [Id. ¶¶ 117–18 (citation omitted)].

1 Plaintiffs cite examples of Defendants’ alleged upcoding in paragraphs 73–86 [Doc. 1 ¶¶ 73–86]. Furthermore, Plaintiffs accuse Defendants of billing for services performed by non-physicians as if the service was performed by physicians [Id. ¶ 123].

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UnitedHealthcare Services, Inc., United Healthcare Insurance Co., and UMR, Inc. v. Team Health Holdings, Inc., Ameriteam Services, LLC, and HCFS Health Care Financial Services, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/unitedhealthcare-services-inc-united-healthcare-insurance-co-and-umr-tned-2025.