Case: Health & Welfare Benefits/ERISA Preemption (N.D. Cal.)

State-law claims stemming from Cigna Corp. behavioral health unit’s reimbursement rates for out-of-network “intensive outpatient program” treatments are preempted by ERISA, the U.S. District Court for the Northern District of California held. The court rejected allegations that Cigna sought to fix prices by engaging a third-party “repricer,” Viant Inc., to renegotiate over services it had pledged to reimburse at the “usual and customary” rate. The court dismissed antitrust, racketeering, fraud, conspiracy, and unfair practices claims and said that mental health treatment provider Pacific Recovery Solutions lacks standing to pursue antitrust or racketeering claims against Cigna or Viant.