Houston County Health Care Authority d/b/a Southeast Health v. UnitedHealthcare Insurance Company

Summary

The United States District Court for the Middle District of Alabama grants UnitedHealthcare Insurance Company’s motion to compel arbitration and stay proceedings in a dispute concerning reimbursement for prescription drugs provided under the federal 340B program. The court holds that the parties’ Facility Participation Agreement contains a broad arbitration and delegation provision requiring the arbitrator to decide questions concerning arbitrability, scope, validity, and termination. The case is stayed pending arbitration, with periodic status reports ordered.

Holdings

1. The Facility Participation Agreement contained a valid delegation provision because the parties expressly agreed to submit all questions of arbitrability, including the existence, validity, scope, and termination of the agreement, to the arbitrator and incorporated the AAA's jurisdictional rules.
2. Southeast Health's arguments that the Facility Participation Agreement had been terminated and that its claims fell outside the arbitration clause were questions of arbitrability delegated to the arbitrator, not issues for the district court to decide.
3. The court granted United's motion to compel arbitration and stayed all of Southeast Health's claims pending completion of arbitration.

Questions Presented

1. Whether the Facility Participation Agreement contained an enforceable delegation provision assigning questions concerning the agreement's existence, validity, scope, and termination to the arbitrator.
2. Whether Southeast Health's challenges to termination of the Facility Participation Agreement and the applicability of its arbitration clause presented delegated questions of arbitrability.
3. Whether the court was required to compel arbitration and stay the action under the Federal Arbitration Act.

Disposition

remanded