Lifecare Mgmt. Svcs., LLC v. Ins. Mgmt. Admins. Inc, et al, No. 11-10733 (5th Cir. 2013)
Annotate this CaseA third-party administrator of medical benefits plans, IMA, denied claims made on behalf of two patients who received treatment from the same medical provider, LifeCare. The court held that IMA incorrectly interpreted the plans because it categorized LifeCare as a skilled nursing facility (SNF) without finding that LifeCare "fully meets all of" the plans' seven SNF factors. IMA abused its discretion because categorizing LifeCare as an SNF without considering the seven-factors SNF test contradicted the plain language of the plans. The court found that the district court correctly held that LifeCare could maintain an action against IMA pursuant to 29 U.S.C. 1132(a)(1)(B) and that IMA was liable for exercising actual control over the claims process. The court further held that the district court did not abuse its discretion in awarding attorneys' fees.
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