Danny P. v. Catholic Health Initiatives, No. 16-35609 (9th Cir. 2018)
Annotate this CaseThe Ninth Circuit reversed the district court's grant of summary judgment for defendant in an action challenging an Employee Retirement Income Security Act (ERISA) plan's denial of a claim. The plan denied plaintiff's claim for the cost of an inpatient stay in a residential mental health treatment facility. The panel held that the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act of 2008 did not require that the plan's coverage for stays at licensed inpatient residential treatment facilities had to be no more restrictive than stays at skilled nursing facilities. The panel explained that the Parity Act precluded the plan from deciding that it would provide room and board reimbursement at licensed skilled nursing facilities for medical and surgical patients, but not at residential treatment facilities for mental health patients.
Court Description: Parity Act. The panel reversed the district court’s grant of summary judgment in favor of the defendant in an action challenging an ERISA plan’s denial of a claim for the cost of an inpatient stay at a residential mental health treatment facility. The panel held that the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act required that the plan’s coverage for stays at licensed inpatient residential treatment facilities had to be no more restrictive than stays at skilled nursing facilities. Thus, the Parity Act precluded the plan from deciding that it would provide room and board reimbursement at licensed skilled nursing facilities for medical and surgical patients, but not at residential treatment facilities for mental health patients. The panel remanded the case to the district court.
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