Jamie F. v. UnitedHealthcare Insurance Company

Background

Jamie F. sought entry of judgment after the court had already granted judgment in her favor on her claim against UnitedHealthCare Insurance Company for benefits under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. § 1001 et seq. The claim concerned residential treatment at Avalon Hills. Jamie F. requested benefits based on the $208,250 amount billed by Avalon Hills or, alternatively, on the rate that would have been used under a single case agreement for treatment by a non-network provider.

Benefits Award

The court held that awarding the entire $208,250 billed amount was not consistent with ERISA’s provision allowing recovery of benefits due under the plan. The court noted that Jamie F. had not established that the plan would have paid the full amount billed by Avalon Hills.

The court found that evidence of four single case agreements approved by UnitedHealthCare for residential treatment at Avalon Hills supported a daily rate of $1,195. Applying that rate to 119 days of treatment, the court awarded Jamie F. $142,205 in benefits.

Prejudgment Interest

The court awarded prejudgment interest, which compensates for losses caused by delayed payment before judgment. For the portion of the treatment costs that Jamie F.’s parents had paid, the court accepted a 3.5 percent annual rate and awarded $11,586.12 in interest. For the remaining portion of the benefits award payable to Avalon Hills, the court accepted a 9 percent annual rate and awarded $4,114.25 in interest. The total prejudgment-interest award was $15,700.37.

Disposition

The court entered judgment for Jamie F. and awarded $142,205 in benefits plus $15,700.37 in prejudgment interest. It also granted Jamie F.’s administrative motion to seal and vacated the hearing scheduled for November 24, 2020.