THE CHATTANOOGA-HAMILTON COUNTY HOSPITAL AUTHORITY D/B/A ERLANGER HEALTH SYSTEM v. UNITEDHEALTHCARE PLAN OF THE RIVER VALLEY, INC. D/B/A AMERICHOICE - Articles

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THE CHATTANOOGA-HAMILTON COUNTY HOSPITAL AUTHORITY D/B/A ERLANGER HEALTH SYSTEM v. UNITEDHEALTHCARE PLAN OF THE RIVER VALLEY, INC. D/B/A AMERICHOICE

Posted by: Azya Thornton on Feb 26, 2025

Court: TN Court of Appeals

Attorneys 1: Steven A. Riley, Gregory S. Reynolds, James N. Bowen, Milton S. McGee, III, Joshua S. Bolian, and Grace C. Peck, Nashville, Tennessee, for the appellant, The Chattanooga- Hamilton County Hospital Authority d/b/a Erlanger Health System.

Attorneys 2: William H. Jordan, Wade P. Miller, Matthew Dowell, R. Joseph Burby, IV, and Rachel D. Leff, Atlanta, Georgia, and W. Scott Sims, Nashville, Tennessee, for the appellee, UnitedHealthcare Plan of The River Valley, Inc. d/b/a AmeriChoice.

Judge(s): MCBRAYER

An out-of-network hospital sued a TennCare managed care organization (“MCO”), seeking additional payment for healthcare services rendered to the MCO’s members. The MCO moved for summary judgment on the hospital’s claims for payment for post-stabilization services provided to both existing and retroactive members. With respect to the existing members, the MCO argued that the hospital could not show that the MCO had a legal obligation to pay for the post-stabilization services at issue. So the hospital could not establish that the MCO was unjustly enriched. The trial court agreed and summarily dismissed these claims. It also certified the dismissal as final. We vacate the dismissal and remand for further proceedings.

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