Wang v. United Healthcare of Washington Inc

CourtDistrict Court, W.D. Washington
DecidedFebruary 24, 2025
Docket2:23-cv-01434
StatusUnknown

This text of Wang v. United Healthcare of Washington Inc (Wang v. United Healthcare of Washington Inc) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Wang v. United Healthcare of Washington Inc, (W.D. Wash. 2025).

Opinion

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5 6 7 UNITED STATES DISTRICT COURT 8 WESTERN DISTRICT OF WASHINGTON AT SEATTLE 9 10 WEIHAN WANG, CASE NO. 2:23-cv-01434-LK 11 Plaintiff, ORDER GRANTING PLAINTIFF’S 12 v. MOTION TO REMAND AND DEFENDANT’S MOTION TO 13 UNITED HEALTHCARE OF STRIKE WASHINGTON, INC., 14 Defendant. 15 16 This matter comes before the Court on Plaintiff Weihan Wang’s motion to remand, Dkt. 17 No. 9, and Defendant UnitedHeathcare of Washington, Inc.’s motion to strike Dr. Wang’s notice 18 of supplemental authority, Dkt. No. 31. The Court grants both motions. 19 I. BACKGROUND 20 A. Facts of the Case 21 Dr. Wang, who is proceeding in this action pro se, is an optometrist who operates a solo 22 practice in Renton, Washington. Dkt. No. 1-1 at 4. His patients include Medicare-eligible 23 individuals who are covered under United Medicare plans. Id. 24 1 In May 2017, Dr. Wang entered into a Medical Group Participation Agreement (the 2 “Agreement”) with United. See Dkt. No. 12-1. Under the Agreement, Dr. Wang and all other 3 physicians in his medical group agreed to “participate with [United] under one contract, one Tax 4 Identification Number (TIN) and one fee schedule(s).” Id. at 1. United agreed to pay for services

5 that Dr. Wang provided to United customers enrolled in certain benefit contracts, including 6 Medicare Advantage Benefit Contracts. Id. at 7–8, 15, 17. As discussed in greater detail below, 7 Medicare Advantage Benefit Contracts are “sponsored, issued or administered” by Medicare 8 Advantage Organizations (“MAOs”) as part of the Medicare Advantage program under Part C (or 9 under Part C in concert with Part D) of Medicare. Id. at 17. Under the Agreement, Dr. Wang was 10 required to submit any claims he had for payment for services rendered to United “within 90 days 11 of the date of service.” Id. at 7. The Agreement also specifies that “in the case of a billing dispute 12 that has been timely-made by [Dr. Wang], [United] shall render a decision within sixty days of 13 receipt of [Dr. Wang’s] complaint,” and “[a] complaint that has been rejected by [United] or any 14 dispute [United] ha[s] with [Dr. Wang] relating to the terms of this Agreement may be submitted

15 to nonbinding mediation.” Id. at 44. “If the parties are unable to resolve a [d]ispute through 16 nonbinding mediation, and if either party wishes to pursue the [d]ispute, such party may commence 17 litigation proceedings”; provided, however, that “[i]n no event shall any litigation be commenced 18 more than one year after the date on which notice of the [d]ispute was given.” Id. at 44–45. 19 The Agreement states that if Dr. Wang’s services “are denied or otherwise not paid . . . due 20 to [his] failure to notify [United], to file a timely claim, to submit a complete claim, to respond to 21 [United’s] request for information, or based on [United’s] reimbursement policies and 22 methodologies, [Dr. Wang] may not charge our customer.” Id. at 41. 23 On September 10, 2020, Dr. Wang rendered services to a patient who was enrolled in one

24 of United’s benefit contracts. Dkt. No. 1-1 at 5. The patient’s insurance card indicated that they 1 were insured under a Part C plan administered by United; however, their primary care provider 2 was an entity called Virginia Mason PCP (PCN) – CMG (“Virginia Mason”). Dkt. No. 23-1 at 2. 3 On November 18, 2020, Dr. Wang submitted a claim to United for the services rendered to the 4 Medicare patient. Dkt. No. 1-1 at 5. Two days later, United sent Dr. Wang a letter stating that

5 Virginia Mason, as opposed to United, was financially responsible for the claim based on other 6 “contractual agreements that exist.” Id. at 5, 27. The letter stated that United forwarded Dr. Wang’s 7 claim to Virginia Mason. Id. On May 16, 2023, having received no further communications or 8 payment from United or Virginia Mason, Dr. Wang notified United via email that the claim 9 remained unresolved and requested payment. Id. at 5. “After some discussion and negotiations,” 10 United notified Dr. Wang on June 2, 2023 that it was not willing to pay on the claim and would 11 not engage in mediation regarding the disputed payment because Dr. Wang did not initiate 12 mediation within a year after he received the November 20, 2020 letter. Id. at 23. 13 On June 5, 2023, Dr. Wang filed a pro se notice of small claims against United in King 14 County District Court, alleging breach of contract. Id. at 1. On September 12, 2023, United

15 removed Dr. Wang’s action to this Court pursuant to 28 U.S.C. §§ 1331, 1441, 1446, and 42 U.S.C. 16 § 405. Dkt. No. 1 at 1. In its notice of removal, United argues that this Court has jurisdiction 17 because Dr. Wang’s claims “arise from” United’s performance of its federal contract with the 18 Centers for Medicare & Medicaid Services (“CMS”) to process Medicare claims under the 19 Medicare Act or are otherwise preempted by the Medicare Act. Id. at 2–4. 20 On September 17, 2023, Dr. Wang filed a motion to remand the case to small claims court. 21 Dkt. No. 9 at 2–11. Two days later, United filed a motion to dismiss. Dkt. No. 10 at 3–16. On 22 December 27, 2024, Wang filed a notice of supplemental authority directing the Court’s attention 23 to certain manuals purportedly containing information about administrative appeal rights under the

24 Medicare regulations. Dkt. No. 30 at 2–3. On January 17, 2025, United moved to strike Wang’s 1 notice of supplemental authority as untimely and because it advanced argument in violation of 2 Local Civil Rule 7(n). Dkt. No. 31 at 1–2. United also filed its own notice of supplemental 3 authority of “cases in this Circuit that post-date United’s Motion to Dismiss and support the 4 principle that this Court has subject matter jurisdiction over this case, both because of ‘arising

5 under’ jurisdiction and federal officer jurisdiction.” Id. at 1; see also Dkt. No. 32 (United’s notice 6 of supplemental authority). 7 B. Medicare Advantage (Medicare Part C) 8 In 1965, Congress passed the Medicare Act to create a federal health insurance program 9 primarily benefitting individuals 65 years of age and older. See 42 U.S.C. § 1395 et. seq. When it 10 was enacted, Medicare consisted of only two parts—Parts A and B (referred to as “traditional 11 Medicare”)—under which the federal government paid health care providers directly for services 12 rendered to Medicare beneficiaries. See 42 U.S.C. §§ 1395c–1395i-5 (Part A), 1395j–1395w-6 13 (Part B). Congress has since also authorized Part C (42 U.S.C. §§ 1395w-21–29), which created 14 the Medicare Advantage program, and Part D (42 U.S.C. §§ 1395w-101–154), which provides

15 prescription drug coverage for Medicare enrollees. Medicare is administered by CMS, an agency 16 within the U.S. Department of Health & Human Services. 17 As discussed above, this case concerns Part C. Under Part C, Medicare enrollees receive 18 Medicare through private organizations called MAOs. CMS enters into contracts with MAOs, see 19 42 U.S.C. § 1395w-27

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Bluebook (online)
Wang v. United Healthcare of Washington Inc, Counsel Stack Legal Research, https://law.counselstack.com/opinion/wang-v-united-healthcare-of-washington-inc-wawd-2025.