York v. Wellmark, Inc., No. 19-1705 (8th Cir. 2020)
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Plaintiffs filed a putative class action, asserting breach of contract claims under Iowa law and breach of fiduciary duty claims under the Employee Retirement Income Security Act (ERISA), based on allegations that Wellmark violated the Patient Protection and Affordable Care Act's (ACA) mandate's cost-sharing and "information and disclosure" requirements. The district court dismissed the information and disclosure claims for failure to state a claim and granted Wellmark summary judgment on the cost-sharing claims.
The Eighth Circuit affirmed and held that the district court accurately noted that neither the ACA's statutory mandate nor its implementing regulations requires the disclosure of information -- including a list of providers -- or prohibits "administrative barriers" or "inconsistent guidance." Rather, the mandate provides that group health plans and health insurance issuers "shall, at a minimum provide coverage for and shall not impose any cost sharing requirements for" preventive health services. The court also held that the summary judgment record established that defendant provided plaintiffs qualified, available in-network providers of comprehensive lactation support and consulting services and did not violate the ACA's cost-sharing mandate.
Court Description: [Loken, Author, with Smith, Chief Judge, and Gruender, Circuit Judge] Civil case - Affordable Care Act. The ACA did not require defendant to provide plaintiffs with disclosure of information, including a list of approved in-network lactation counseling providers, and failure to provide the list did not amount to a failure to provide coverage as mandated by the ACA; plaintiff Bailey's information and disclosure claim under ERISA failed to state a claim upon which could be granted; the summary judgment record established that defendant provided the plaintiffs qualified, available in-network providers of comprehensive lactation support and consulting services and did not violate the ACA's cost-sharing mandate.
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