Hospice of Metro Denver, Inc. v. Group Health Insurance of Oklahoma, Inc.

Summary

The Tenth Circuit held that a health care provider’s promissory estoppel claim against an insurer based on assurances of coverage was not preempted by ERISA. The court reversed the dismissal and remanded with instructions to return the case to Colorado state court; it denied the provider’s requests for sanctions, attorney’s fees, and costs.

Holdings

1. ERISA § 514(a) does not preempt a state-law claim by a third-party health care provider seeking payment from an insurer based on the insurer's alleged misrepresentation or promise of coverage when the claim does not seek to enforce or modify the ERISA plan, affect plan administration, or implicate the rights of plan participants or beneficiaries.
2. Hospice's requests for attorney's fees, sanctions, and costs were denied.

Questions Presented

1. Whether ERISA § 514(a), 29 U.S.C. § 1144(a), preempted a third-party health care provider's state-law promissory estoppel claim against an insurer based on alleged assurances of payment.
2. Whether Hospice's requests for attorney's fees, sanctions, and costs should be granted on appeal.

Disposition

reversed_and_remanded