Unilab Corp. v. Angeles-IPA
Annotate this CaseQuest filed suit seeking payment from Angeles for out-of-network laboratory testing services ordered by in-network physicians for Angeles patients. The trial court granted summary adjudication for Angeles for all but two causes of action that were subsequently dismissed. Summary judgment was then entered for Angeles. The court concluded that the referral of specimens to Quest by Angeles physicians who either misidentified the patient‘s IPA/payor or failed to identify an IPA/payor at all did not create an implied-in-fact contract that Angeles would pay for the tests; there is no evidence of an agency relationship between Angeles and its in-network physicians; Angeles does not exercise control over the manner in which the physicians provide medical care to their patients; and the physicians who used Quest drop boxes after the November 30, 2009 termination date did so based on their membership in a Quest-affiliated IPA, their mistaken belief that the patient also belonged to that IPA, or some other error. The court also concluded that there is no implied-in-law or quasi-contract where there is no evidence that Angeles actually paid its in-network laboratory a lower capitation rate as a result of the work that was misdirected to Quest and Quest has not identified a statute or regulation that requires an IPA to pay an out-of-network laboratory where there is no contractual obligation to do so. The court rejected Quest's remaining claims and affirmed the judgment.
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