Chattanooga-Hamilton County Hosp. Auth. v. UnitedHealthcare Plan of the River Valley, Inc.

A Hospital brought this lawsuit against a TennCare managed care organization (MCO), alleging that the MCO had not paid the Hospital all it was due for emergency services provided to the MCO’s TennCare enrollees. The MCO counterclaimed, seeking recovery of alleged overpayments made pursuant to the TennCare regulations. Thereafter, the MCO filed a motion for partial summary judgment, arguing that the Uniform Administrative Procedures Act (UAPA) required the Hospital to exhaust its administrative remedies by bringing its claims before TennCare prior to filing suit. The trial court agreed and dismissed the Hospital’s complaint and the MCO’s counterclaim for lack of subject matter jurisdiction. The Supreme Court reversed, holding (1) the UAPA requires exhaustion of administrative remedies in this matter to the extent that resolution of the parties’ claims would require the trial court to render a declaratory judgment concerning the validity or applicability of TennCare regulations; but (2) while the UAPA prohibits the trial court from rendering such declaratory relief absent exhaustion of administrative remedies, it does not address claims for damages. Remanded to the trial court with directions to hold the parties’ damage claims in abeyance pending resolution of administrative proceedings regarding the validity or applicability of the TennCare regulations at issue. View "Chattanooga-Hamilton County Hosp. Auth. v. UnitedHealthcare Plan of the River Valley, Inc." on Justia Law