Springer v. Cleveland Clinic Employee Health Plan Total Care, No. 17-4181 (6th Cir. 2018)Annotate this Case
Springer, a Utah physician, began a fellowship at the Cleveland Clinic and enrolled his family in its employee benefit plan, administered by Antares. During the enrollment period, Springer had his 14-month-old son, J.S., transported from a Utah hospital to the Cleveland Clinic by Angel Jet’s air ambulance service. J.S. had been hospitalized since birth for multiple congenital abnormalities. He required a mechanical ventilator. J.S.’s physician prepared a letter of medical necessity for the service. Before the flight, Angel Jet contacted Antares, which was unable to confirm that Springer and his son were members of the plan and did not precertify the service. Angel Jet proceeded with the transportation and submitted a bill to Antares for $340,100. Antares denied it for failure to obtain precertification. The Plan affirmed the denial but paid $34,451.75, reflecting the amount their preferred provider would have charged. Angel Jet brought suit under the Employee Retirement Security Act. The district court dismissed the suit, finding that Springer had not properly assigned his rights under the plan to Angel Jet. Springer then brought his own claim under ERISA Section 502(a)(1)(B). The Sixth Circuit affirmed, first finding that Springer had standing despite having received the service and not being billed. The denial was not arbitrary and capricious because J.S.’s transportation was not an emergency or precertified as required for a nonemergency.