Worldwide Aircraft Services Inc. v. Secretary of the United States Department of Health and Human Services

CourtDistrict Court, M.D. Florida
DecidedFebruary 4, 2025
Docket8:24-cv-02156
StatusUnknown

This text of Worldwide Aircraft Services Inc. v. Secretary of the United States Department of Health and Human Services (Worldwide Aircraft Services Inc. v. Secretary of the United States Department of Health and Human Services) is published on Counsel Stack Legal Research, covering District Court, M.D. Florida primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Worldwide Aircraft Services Inc. v. Secretary of the United States Department of Health and Human Services, (M.D. Fla. 2025).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA TAMPA DIVISION

WORLDWIDE AIRCRAFT SERVICES INC., d/b/a JET ICU, a Florida corporation,

Plaintiff,

v. Case No. 8:24-cv-02156-WFJ-LSG

Secretary of Health and Human Services and Administrator for the Centers for Medicare and Medicaid Services,1

Defendants. _________________________________/

ORDER Before the Court is the Secretary of the United States Department of Health and Human Services (“HHS”) and Administrator for the Centers for Medicare and Medicaid Services’ (“CMMS”) Motion to Dismiss the Complaint filed by Plaintiff Worldwide Aircraft Services, Inc. d/b/a Jet ICU (“Jet ICU” or the “Plaintiff”) pursuant to Federal Rule of Civil Procedure 12(b)(6). Dkt. 18. Jet ICU has responded in opposition. Dkt. 19. As explained below, Defendants’ motion to dismiss is granted.

1 Given the change in presidential administration, the caption was changed pursuant to Fed. R. Civ. P. 17(d) and 25(d). Because Senate confirmations for HHS and CMMS are currently pending, the Court requests the caption be updated to reflect any changes pursuant to the same rules once the confirmations are complete. BACKGROUND I. The No Surprises Act

During a medical emergency, there is little choice in how a patient will get to a hospital. In some cases, the patient receives expensive transportation from a provider—like an air ambulance—who is outside the patient’s insurance network.

When the bill comes due, the patient’s insurance and out-of-network provider may not agree on a fair reimbursement for the cost of services. In 2020, Congress attempted to resolve this problem with the No Surprises Act (the “NSA”), which created a uniform reimbursement process, including binding arbitration. See 42

U.S.C. § 300gg-111. As relevant here, the NSA establishes a dispute resolution system for when healthcare providers and insurers dispute surprise medical bills. 42 U.S.C. § 300gg-

111(c)(1)–(5). This system is known as the Independent Dispute Resolution (“IDR”) process and generally has four steps: [1] provider and the insurer negotiate the price for the service, 42 U.S.C. § 300gg-111(c)(1)(A); [2] if these negotiations fail, the provider and insurer have four days to begin the IDR process, id. § 300gg-

111(c)(1)(B); [3] a certified IDR entity is selected by either the parties or the Department of HHS, id. § 300gg-111(c)(4); and [4] the certified IDR entity determines whether the parties’ dispute is eligible for IDR and then decides the

amount owed to the provider by the insurer, id. § 300gg-111(c)(5). The same four step process applies to air ambulance insurance claims. See id. § 300gg-112. The air ambulance company can negotiate with the insurance provider

for payment, id. § 300gg-112(b)(1)(A), and if the negotiations fail, the parties go to the same IDR process for “baseball style” arbitration. Id. § 300gg-112(b)(1)(B); Med-Trans Corp. v. Cap. Health Plan, Inc., 700 F. Supp. 3d 1076, 1079–80 (M.D.

Fla. 2023), appeal dismissed, 2024 WL 3402119 (11th Cir. May 30, 2024). Importantly, the NSA’s protections for patients only extend to services and items covered under the terms of a patient’s health insurance plan. See 42 U.S.C. § 300gg-112(a) (“In the case of a participant, beneficiary, or enrollee who is in a group

health plan or group or individual health insurance coverage offered by a health insurance issuer and who receives air ambulance services from a nonparticipating provider . . . with respect to such plan or coverage, if such services would be covered

if provided by a participating provider . . . with respect to such plan or coverage. . .” (emphasis added)); 45 C.F.R. § 149.130(a) (“If a group health plan, or a health insurance issuer offering group or individual health insurance coverage, provides or covers any benefits for air ambulance services, the plan or issuer must cover such

services from a nonparticipating provider of air ambulance services . . .” (emphasis added)). II. Certified IDR Entity Determinations The NSA charges the Departments of HHS, Labor, and Treasury (the

“Departments”) with establishing regulations to flesh out the dispute resolution process. See 42 U.S.C. § 300gg-112(b)(2)(A). Specifically, the Departments “shall establish by regulation,” no later than December 27, 2021, “one independent dispute

resolution process . . . under which” an independent arbitrator, known in the NSA as a certified IDR entity (“CIDRE”), “determines, . . . in accordance with the succeeding provisions of this subsection, the amount of payment under the plan or coverage for such services furnished by such provider.” Id.; see also 86 Fed. Reg. at

36,883 (“With respect to air ambulance services furnished by nonparticipating providers . . . [insurers] must comply with the requirements regarding cost sharing, payment amounts, and processes for resolving billing disputes . . . , if such services

would be covered if provided by a participating provider with respect to such plan or coverage.”). The subsequent regulations promulgated by the Departments require the insurer to first determine whether the services rendered are covered under a patient’s

healthcare plan “and, if the services are covered, send to the provider an initial payment or a notice of denial of payment.” 45 C.F.R. § 149.130(b)(4)(i). If the out-of-network air ambulance provider disagrees with the insurer, the

provider can send a notice of IDR initiation to the HHS Secretary. 42 U.S.C. § 300gg-112(b)(1)(B) (requiring the initiating party to submit to the other party and the Secretary a notification “containing such information as specified by the

Secretary.”). In the notice of IDR initiation, the parties must provide information sufficient to show that the item or service in dispute is a “qualified IDR item or service.” See 45 C.F.R. § 149.510(b)(2)(iii)(A)(1). Indeed, CIDREs are required to

determine whether the air transportation was a “qualified IDR air ambulance service” because an air ambulance provider can only participate in the federal IDR process if the patient’s plan covers such services. See 42 U.S.C. § 300gg- 112(b)(5)(A) (limiting IDR payment determinations to “a determination for

qualified IDR ambulance services,” which are services that would be covered if provided by a participating provider with respect to such plan or coverage); 45 C.F.R. § 149.510(c)(1)(v) (“[T]he certified IDR entity selected must review the

information submitted in the notice of IDR initiation to determine whether the Federal IDR process applies.”).

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