Arapahoe Surgery Ctr., LLC v. Cigna Healthcare, Inc. — Mar. 2016 (Summary)

ANTITRUST

Arapahoe Surgery Ctr., LLC v. Cigna Healthcare, Inc.
Civil Action No. 13-CV-3422-WJM-CBS (D. Colo. Mar. 21, 2016)

The United States District Court for the District of Colorado granted in part and denied in part an insurance company’s motion for summary judgment on claims made by a second insurance company under antitrust law and the Employee Retirement Income Security Act (“ERISA”). This litigation arose from disputes over the handling of billing, payment, and fee-forgiving procedures for patients with no in-network responsibility. The court reasoned that because of a lack of evidence of an antitrust injury there was no way a reasonable jury could find in the second insurance company’s favor on its antitrust claims. The court also reasoned that the second insurance company’s ERISA claims were barred for failure to exhaust administrative remedies as to any claim for benefits that was not appealed through both administrative levels under the plans in dispute.