In Ryan S. v. UnitedHealth Group Inc., 2024 U.S. App. LEXIS 8729, the Ninth Circuit Court overturned a lower court decision and found that UnitedHealth Group (UHG). must face a class action suit alleging it violated the Mental Health Parity and Addiction Equity Act. The suit alleges that UHG applied a more stringent standard of review to mental health and substance use disorder claims than to medical or surgical claims. The suit cites a report by the California Department of Managed Health Care that UHG used an algorithm to assess a patient's progress in a mental health program and to refer claims identified by the algorithm for additional review. UHG did not conduct the same additional review process for medical or surgical claims.
The Court affirmed the district court’s dismissal of the plaintiff’s claim regarding breach of the plan’s terms. The Court reversed the district court’s dismissal of the plaintiff’s claims for breach of the Parity Act and ERISA fiduciary duty provisions. The Court remanded the case to the district court for further proceedings consistent with this opinion. The district court case is pending in the Central District of California, No. 8:19-cv-0136.