Marietta Mem'l Hosp. Emp. Health Benefit Plan v. DaVita Inc.

When health care plan terms are applied uniformly to all plan participants, the plan does not violate the Medicare Secondary Payer statute because it does not “differentiate in the benefits it provides” or takes into account Medicare eligibility.

Petitioners provided a health care plan that included a limited payment for outpatient dialysis treatment for all plan participants. Respondents argued that the limited coverage violates the Medicare Secondary Payer statute because it has a disproportionate effect on end stage renal disease patients and it takes into account that those patients are eligible for Medicare. The Sixth Circuit reversed the District Court’s decision, finding that Petitioners' plan had a disparate-impact for end stage renal disease patients. On appeal, the Supreme Court reversed, holding that health plans that uniformly provide benefits to all participants does not violate the Medicare Secondary Payer statute. The Court reasoned that the staute's language states that insurance providers cannot “differentiate” between patients with end stage renal disease and other patients, and because Petitioners’ plan uniformly provides limited payments to all plan participants regardless of their disease, it neither differentiated between patients nor took into account Medicare eligibility. Furthermore, the Court reasoned that the statute's plain text did not include a disparate-impact clause. Therefore, Petitioner’s plan did not violate the Medicare Secondary Payer statute. REVERSED and REMANDED.