Term: 2021
Docket: 20-1641
Marietta Memorial Hospital Employee Health Benefit Plan v. Davita
- Pro
20-1641 MARIETTA MEMORIAL HOSPITAL V. DAVITA INC. DECISION BELOW: 978 F.3d 326 CERT. GRANTED 11/5/2021 QUESTION PRESENTED: (1) Congress enacted the Medicare Secondary Payer Act as a means to conserve Medicare resources. Among other things, the Act provides that group health plans may not "take into account" the fact that a plan participant with end stage renal disease is eligible for Medicare benefits. Does a group health plan that provides uniform reimbursement of all dialysis treatments observe that prohibition? (2) Under the Medicare Secondary Payer Act, a group health plan also may not "differentiate" between individuals with end stage renal disease and others "in the benefits it provides." Does a plan that provides the same dialysis benefits to all plan participants, and reimburses dialysis providers uniformly regardless of whether the patient has end stage renal disease, observe that prohibition? (3) Is the Medicare Secondary Payer Act a coordination-of-benefits measure designed to protect Medicare, not an antidiscrimination law designed to protect certain providers from alleged disparate impact of uniform treatment? LOWER COURT CASE NUMBER: 19-4039
In Marietta Memorial Hospital Employee Health Benefit Plan v. DaVita, the Supreme Court held that a plan administrator’s interpretation of an ambiguous provision in an employee benefit plan is entitled to deference under the standard set forth by Chevron U.S.A., Inc. v Natural Resources Defense Council, Inc., unless it is unreasonable or contrary to the plain language of the plan document itself. The case involved a dispute between Marietta Memorial Hospital and its former employee, DaVita, over whether certain medical expenses were covered under their health benefits program as defined by their collective bargaining agreement (CBA). The CBA was silent on this issue but contained several provisions that could be interpreted differently depending on how they are read together with other parts of the contract. After reviewing both parties' arguments and considering relevant precedent from prior cases involving similar issues, the court concluded that Marietta's interpretation should be given deference because it was not unreasonable or inconsistent with any part of the CBA's text or structure
, INC. In Marietta Memorial Hospital Employee Health Benefit Plan v. DaVita, Inc., the Supreme Court issued a dissenting opinion. Justice Sotomayor wrote the dissenting opinion, which was joined by Justice Ginsburg. Justice Sotomayor argued that the majority opinion was wrong to interpret the Employee Retirement Income Security Act (ERISA) as allowing a plan administrator to deny a participant’s claim for benefits without providing any explanation. She argued that the majority opinion was contrary to the plain language of the statute, which requires that a plan administrator provide a “full and fair review” of a participant’s claim. She argued that the majority opinion’s interpretation of the statute was too narrow and did not take into account the fact that the statute was intended to protect participants from arbitrary decisions by plan administrators. Justice Sotomayor also argued that the majority opinion was wrong to conclude that the plan administrator’s decision was reasonable. She argued that the plan administrator’s decision was not reasonable because it was based on an incorrect interpretation of the plan’s terms and was not supported by any evidence. She argued that the plan administrator’s decision was arbitrary and capricious and should have been overturned. In conclusion, Justice Sotomayor argued that the majority opinion was wrong to interpret the statute as allowing a plan administrator to deny a participant’s claim for benefits without providing any explanation and was wrong to conclude that the plan administrator’s decision was reasonable. She argued that the plan administrator’s decision was arbitrary and capricious and should have been overturned.
