Olivia Reyes v. Florida Keys Aqueduct Authority

Summary

The Florida Third District Court of Appeal affirmed summary judgment for the Florida Keys Aqueduct Authority in a dispute over coverage under a self-funded governmental health plan. The court held that undisputed medical records established that the appellant’s hospitalization resulted from complications of excluded elective cosmetic surgery. It also held that the Patient Protection and Affordable Care Act did not require the governmental self-funded plan to cover the emergency services at issue.

Holdings

1. Summary judgment for FKAA was proper because the undisputed evidence established that Reyes's hospitalization and treatment resulted from complications of her elective cosmetic surgery, which the plan excluded from coverage.
2. The PPACA's essential-health-benefit requirements do not require a self-funded health plan maintained by a governmental entity to provide coverage for emergency medical services.
3. Issues concerning FKAA's compliance with state law that were raised for the first time on appeal were waived and were not properly preserved for appellate review.

Questions Presented

1. Whether summary judgment was proper where the undisputed hospital records established that Reyes's hospitalization resulted from complications of elective cosmetic surgery excluded by the health plan.
2. Whether the Patient Protection and Affordable Care Act required FKAA's self-funded governmental health plan to cover Reyes's emergency medical services.
3. Whether new issues concerning FKAA's compliance with state law were preserved for appellate review.

Disposition

affirmed