Usable Mutual Insurance Co. (d/B/A Arkansas Blue Cross Blue Shield), Usable Corp. (d/B/A True Blue Ppo, Arkansas Firstsource, and Preferred Provider Networks of Arkansas), and Hmo Partners, Inc. (d/B/A Health Advantage Hmo Arkansas) v. Adam Stibich, M.D.

2024 Ark. App. 510, 699 S.W.3d 180
CourtCourt of Appeals of Arkansas
DecidedOctober 23, 2024
StatusPublished
Cited by2 cases

This text of 2024 Ark. App. 510 (Usable Mutual Insurance Co. (d/B/A Arkansas Blue Cross Blue Shield), Usable Corp. (d/B/A True Blue Ppo, Arkansas Firstsource, and Preferred Provider Networks of Arkansas), and Hmo Partners, Inc. (d/B/A Health Advantage Hmo Arkansas) v. Adam Stibich, M.D.) is published on Counsel Stack Legal Research, covering Court of Appeals of Arkansas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Usable Mutual Insurance Co. (d/B/A Arkansas Blue Cross Blue Shield), Usable Corp. (d/B/A True Blue Ppo, Arkansas Firstsource, and Preferred Provider Networks of Arkansas), and Hmo Partners, Inc. (d/B/A Health Advantage Hmo Arkansas) v. Adam Stibich, M.D., 2024 Ark. App. 510, 699 S.W.3d 180 (Ark. Ct. App. 2024).

Opinion

Cite as 2024 Ark. App. 510 ARKANSAS COURT OF APPEALS DIVISION III No. CV-23-372

USABLE MUTUAL INSURANCE CO. Opinion Delivered October 23, 2024

(D/B/A ARKANSAS BLUE CROSS APPEAL FROM THE PULASKI BLUE SHIELD), USABLE CORP. COUNTY CIRCUIT COURT, FOURTH (D/B/A TRUE BLUE PPO, ARKANSAS DIVISION FIRSTSOURCE, AND PREFERRED [NO. 60CV-20-2525] PROVIDER NETWORKS OF ARKANSAS), AND HMO PARTNERS, INC. (D/B/A HEALTH ADVANTAGE HONORABLE HERBERT T. WRIGHT, HMO ARKANSAS) JUDGE APPELLANTS

V.

ADAM STIBICH, M.D. APPELLEE APPEAL DISMISSED WITHOUT PREJUDICE

CINDY GRACE THYER, Judge

The appellants in this case, a network of healthcare-insurance providers (collectively,

“the Networks”) appeal from an order of the Pulaski County Circuit Court that granted the

summary-judgment motion filed by appellee Dr. Adam Stibich. At issue is whether the

Networks’ removal of Stibich from their healthcare-provider networks violated Arkansas’s

“Any Willing Provider” (AWP) law, codified at Arkansas Code Annotated sections 23-99-

201 et seq. (Repl. 2014 & Supp. 2023). Because we lack a final order in this case, the appeal

must be dismissed at this time. Stibich is a dermatologist practicing in Garland County. Until May 2019, Stibich

participated in the in-network provider panels of the Networks. As an in-network provider,

Stibich was subject to the terms and conditions of the Networks’ participation agreements.

Among other provisions, those agreements all contained specific language regarding grounds

for termination from participation in the network. In addition, in 2005, the Networks issued

a “Notice of Network Terms and Conditions” (“the Notice”) that was intended to “clarif[y]

and exten[d] current Network Terms and conditions . . . applicable to all qualified individual

providers who participate in” the Networks.

In May 2019, the Networks notified Stibich that they were terminating his network-

participation agreements with them. The Networks all pointed to specific terms and

conditions of the agreements that provided grounds for termination. After Stibich

unsuccessfully appealed the termination through two levels of the Networks’ appeal process,

he filed a complaint against the Networks in the Pulaski County Circuit Court on April 5,

2020. In his complaint, he asserted that the Networks’ termination of his in-network status

violated Arkansas’s AWP laws, which declare that an insurer “shall not, directly or indirectly,

. . . prohibit or limit a healthcare provider that is qualified under [the relevant language in

the statute] and is willing to accept the health benefit plan’s operating terms and conditions

. . . from the opportunity to participate in that health benefit plan.” Stibich asserted he was

a qualified healthcare provider under the relevant statute; therefore, the Networks’

termination of his agreement violated the AWP. Therefore, pursuant to Arkansas Code

2 Annotated section 23-99-207, Stibich sought injunctive relief against the Networks and asked

the circuit court to direct the Networks to reinstate him to their in-network provider panels.1

Stibich subsequently moved for summary judgment on his claim that the Networks

violated the AWP, arguing that the undisputed facts demonstrated that the Networks used

an improper and unlawful standard to terminate his agreements with them. He thus sought

1 Stibich’s complaint also alleged grounds of tortious interference with contractual relationships with in-network patients and tortious interference with business expectancy. The Networks sought to compel arbitration of all of Stibich’s claims, citing language in the provider agreements requiring arbitration “in the event of a dispute between the parties to this Agreement concerning the terms, conditions, performance or non-performance, interpretation, construction, or application of this Agreement, or any issue relating thereto, including but not limited to any dispute concerning Provider’s credentials, qualifications, [or] Network participation status.” The circuit court granted the Networks’ motion to compel arbitration of Stibich’s tortious-interference claims but denied it as to his claim under the AWP, reasoning that the express intent of the legislature was that the enforcement provisions of the AWP “be enforced by the courts.” The court’s order stated, “The [Networks’] motion to compel arbitration on [the AWP] cause of action is denied. The [Networks’] motion to compel arbitration is granted with respect to the tortious interference cause[s] of action.”

Under the Arkansas Arbitration Act, “[i]f the court orders arbitration, the court on just terms shall stay any judicial proceeding that involves a claim subject to the arbitration. If a claim subject to arbitration is severable, the court may limit the stay to that claim.” Ark. Code Ann. § 16-108-207(g) (Repl. 2016). Notably, here, the court’s order did not include language indicating whether the arbitrable claims were stayed. On the record before us, this court is therefore unaware of the status of those claims that were sent to arbitration. Although we are dismissing this appeal for lack of a final order on other grounds, we caution the parties to ensure that any remaining claims, which may or may not still be subject to arbitration, are resolved before attempting to pursue a potential appeal in the future. See, e.g., Fox v. Fox, 2021 Ark. App. 416, at 4 (citing the appellate courts’ policy against considering piecemeal appeals and noting that “even though an issue on which a court renders a decision might be an important one, an appeal will be premature if the decision does not, from a practical standpoint, conclude the merits of the case.”).

3 a judgment declaring his removal from the Networks’ provider panels “void as a matter of

law and ordering the Networks to reinstate him to in-network status immediately.”

The Networks responded to Stibich’s summary-judgment motion, asserting, among

other things, that Stibich failed to make a prima facie case for an injunction under the AWP

and that genuine issues of material fact remained.

The circuit court entered an order on January 9, 2023, granting Stibich’s motion for

summary judgment. The court found that under Arkansas Code Annotated section 23-99-

804 (Supp. 2023), a healthcare provider like Stibich “cannot be excluded from contracting

with a health insurer if they are licensed and in good standing with their respective licensing

board and if they are permitted to participate in Medicare, Medicaid, or any other federal

health benefit plan.” The court also determined that the Networks’ decision to terminate

their agreements with Stibich was not conducted in a fair and nondiscriminatory manner,

in violation of the AWP. The court thus determined that there were no material questions

of fact in dispute and that Stibich’s motion for summary judgment should be granted.

The same day the court’s order was entered, Stibich wrote to the Networks, arguing

that in light of the court’s ruling, he expected to be reinstated to the Networks

“immediately.” The Networks replied that although the court’s order granted Stibich’s

motion for summary judgment, they had “not been directed by the Court to reinstate Dr.

Stibich at this point. The summary judgment order does not enter an injunction or even

mention injunctive relief.”

4 Stibich then filed a motion on January 18, 2023, asking the court to amend its order

to expressly provide relief in the form of a directive to the Networks to immediately reinstate

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Seaside Pools, Inc. v. Robert Lee Curtis, Jr., and Sheila Dawn Curtis
2025 Ark. App. 155 (Court of Appeals of Arkansas, 2025)

Cite This Page — Counsel Stack

Bluebook (online)
2024 Ark. App. 510, 699 S.W.3d 180, Counsel Stack Legal Research, https://law.counselstack.com/opinion/usable-mutual-insurance-co-dba-arkansas-blue-cross-blue-shield-usable-arkctapp-2024.