Griffin v. Teamcare

Federal 7th Circuit Court
Civil Court
ERISA
Citation
Case Number: 
No. 18-2374
Decision Date: 
November 26, 2018
Federal District: 
N.D. Ill., E. Div.
Holding: 
Affirmed and vacated in part and remanded

Dist. Ct. erred in dismissing plaintiff-doctor’s action under ERISA, alleging that defendant-health care plan underpaid plaintiff for medical services rendered to one of plaintiff’s patients, and that defendant owed statutory penalties based on its failure to timely furnish plan documents upon plaintiff’s request. While Dist. Ct. dismissed plaintiff’s underpayment claim based on plaintiff’s failure to identify specific plan provision that covered services at issue in plaintiff’s claim, plaintiff need not cite in her complaint specific plan provision establishing coverage at amount billed by plaintiff. Also, Ct. rejected Dist. Ct.’s ruling that plaintiff, as assignee of patient-plan participant, could not seek statutory penalties based on defendant’s failure to timely provide requested documents that pertained to defendant’s calculation of plan benefits, since: (1) assignee designated to receive plan benefits is considered beneficiary and can sue for unpaid benefits; and (2) bringing lawsuit against plan for said benefits requires access to information as to how defendant determined usual and customary billing rate.