Articles Posted in U.S. Court of Appeals for the Second Circuit

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Plaintiffs, two individual psychiatrists and three professional associations of psychiatrists, filed suit against defendants, four health‐insurance companies, alleging that the health insurers’ reimbursement practices discriminate against patients with mental health and substance use disorders in violation of the Mental Health Parity and Addition Equity Act of 2008 (MHPAEA), 29 U.S.C. 1185(a), and the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001-1461. The court concluded that, because the psychiatrists are not among those expressly authorized to sue, they lack a cause of action under ERISA. The court also concluded that the association plaintiffs lack constitutional standing to pursue their respective ERISA and MHPAEA claims because their members lack standing. Accordingly, the court affirmed the judgment. View "Am. Psychiatric Ass’n v. Anthem Health Plans, Inc." on Justia Law

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Plaintiff filed a class action against the Commissioner, challenging New York’s coverage restrictions on certain medical services provided under its Medicaid plan. Plaintiffs argued that New York’s 2011 plan amendments, which restrict coverage of orthopedic footwear and compression stockings to patients with certain enumerated medical conditions, violate the Medicaid Act’s, 42 U.S.C. 1396 et seq., reasonable standards, home health services, due process, and comparability provisions, as well as the anti‐discrimination provision and integration mandate of Title II of the Americans with Disabilities Act (ADA), 42 U.S.C. 12131 et seq., and section 504 of the Rehabilitation Act, 29 U.S.C. 794. Because neither the Medicaid Act nor the Supremacy Clause confers a private cause of action to enforce the reasonable standards provision, the court vacated the district court’s grant of summary judgment to plaintiffs on that claim; the court declined to reach plaintiffs’ unequal treatment claim under the ADA and Rehabilitation Act as largely duplicative of their integration mandate claim; and the court affirmed the summary judgment rulings with respect to the remaining claims. Defendant is entitled to summary judgment on plaintiffs' home health services plan because orthopedic footwear and compression stockings constitute optional “prosthetics” rather than mandatory “home health services” under the Medicaid Act; defendant is entitled to summary judgment on the hearing element and plaintiffs are entitled to summary judgment on the notice element of plaintiffs’ due process claim, because the due process provision required New York to provide plaintiffs with written notice – though not evidentiary hearings – prior to terminating their benefits; plaintiffs are entitled to summary judgment on their comparability provision claim because New York’s coverage restrictions deny some categorically needy individuals access to the same scope of medically necessary services made available to others; and plaintiffs are entitled to summary judgment on their anti‐discrimination claims because New York’s restrictions violate the integration mandate of the ADA and Rehabilitation Act. Finally, the court vacated the injunction and remanded for further consideration on the appropriate relief because the injunction is broader than is warranted by the court's liability conclusions. View "Davis v. Shah" on Justia Law

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In 2000, the Secretary of Health and Human Services issued a regulation, known as the “reclassification rule,” 42 C.F.R. 412.230(a)(5)(iii), which provided that a hospital that has been reclassified from urban to rural under the Medicare Act, 42 U.S.C. 1395ww(d)(8)(E), may not thereafter receive an additional reclassification by the Medicare Geographic Classification Review Board (MGCRB) for reclassification as urban under subsection (d)(10). Lawrence filed suit seeking a preliminary injunction to enjoin defendants from applying the Secretary's reclassification rule to Lawrence's MGCRB application. The district court denied the motion. However, the court found the statutory language to be plain and unambiguous, and at odds with the Secretary’s reclassification rule, 42 C.F.R. 412.230(a)(5)(iii). Therefore, the court declared the regulation invalid and reversed the judgment of the district court, remanding for a determination of the appropriate remedy. View "Lawrence + Memorial Hosp. v. Burwell" on Justia Law