On Monday, the Northern District of Illinois issued an opinion denying Anthem Insurance Companies, Inc.’s motion to dismiss in the case of Northwestern Memorial Healthcare v. Anthem Insurance Companies, Inc. et al.
According to the opinion, Northwestern is a not-for-profit public benefit corporation that provides medical care in Illinois through its subsidiary hospitals. Further, the opinion states that the defendants Anthem Insurance Companies, Inc. and Anthem Blue Cross Life and Health Insurance Company (collectively Anthem), operate as health insurance companies .
The opinion states that from September 2018 through January 2021, Northwestern provided medical treatment to sixteen patients, who were members of Anthem’s health plans, totalling $2,427,575.94. Northwestern alleges that it had no express contract with Anthem to provide medical services to those patients, but states that it contacted Anthem to verify each patient’s coverage and obtain authorization to perform the services. The opinion states that Anthem verified that each patient was a member of one of its health plans, authorized each patient’s medical care and approved the admission of each patient.
However, the opinion purports that Anthem only paid $179,596.77 for the services after receiving a bill for the full amount of $2,427,575.94. Northwestern alleges that the full bill represents its usual and customary charges for those services, and that over the past five years Anthem has paid Northwestern the full amount for a number of claims nearly identical in method and manner to those rendered to the 16 Anthem patients.
Subsequently, Northwestern initiated the present lawsuit to recover the remaining balance of the bill under a quantum meruit theory. Anthem then filed a motion to dismiss, arguing that there was no valid contract nor a “meeting of the minds” in which Anthem agreed to pay for the medical services.
In its opinion, the court denied Anthem’s motion to dismiss, holding that there is a genuine dispute of fact whether Anthem impliedly agreed to pay Northwestern’s billed rates in full. The court noted that discovery is necessary to determine whether an implied contract existed and whether Northwestern’s quantum meruit argument is valid. Further, the court stated that the defendants must answer Northwestern’s complaint by June 13, 2022.