Dist. Ct. did not err in finding that plaintiff-dependent of one of defendant’s employees, stated viable cause of action under section 1557 of Patient Protection and Affordable Care Act, where defendants-self-funded health care plan and employer denied coverage for plaintiff’s autism treatment. Plaintiff alleged that defendants discriminated against him on basis of his disability by designing and enforcing terms of health-care plan, which categorically excluded coverage for autism and therapy used to treat it. Ct. of Appeals held that plaintiff’s lawsuit was consistent with section 1557’s text and purpose, where defendants conceded that they are in healthcare business as healthcare provider, and thus fell within zone of interests that section 1557 was meant to protect, where all of defendants’ operations are considered part of health program even if all parts are not federally funded. Ct. rejected defendants’ contention that plaintiff fell outside zone of interests protected by section 1557, because: (1) they received Medicare and Medicaid payments only in conjunction with treatment they gave to their patients as healthcare provider; and (2) plaintiff, as dependent of employee of defendant-employer, fell outside of said zone of interests.
Federal 7th Circuit Court
Civil Court
Patient Protection and Affordable Care Act