Spinedex Physical Therapy v. United Healthcare

A healthcare provider maintains Article III standing to bring claims against an assignee plan beneficiary for denied benefits but not for breach of fiduciary duty.

Some United Healthcare (“United”) plan beneficiaries received physical therapy at Spinedex Physical Therapy (“Spinedex”). Spinedex submitted claims for these treatments to United. Some were paid while others were denied in whole or in part. Spinedex policy allowed recovery of unpaid balances from patients but Spinedex did not exercise this right. In 2008, Spinedex filed a complaint seeking payment of the denied claims from United. Later that year, Spinedex and others filed an amended complaint alleging breaches of fiduciary duty. The assignments give the right to seek payment directly from the plan but no language indicates an assignment of fiduciary rights. Therefore, a healthcare provider maintains Article III standing to bring claims against an assignee plan beneficiary for denied benefits but not for breach of fiduciary duty. REVERSED in part, AFFIRMED in part, VACATED in part, and REMANDED.