Gobeille v. Liberty Mut. Ins. Co.
Supreme Court of the United States
December 2, 2015, Argued; March 1, 2016, Decided
Justice Kennedy delivered the opinion of the Court.
This case presents a challenge to the applicability of a state law requiring disclosure of payments relating to health care claims and other information relating to health care services. Vermont enacted the statute so it could maintain an all-inclusive health care database. Vt. Stat. Ann., Tit. 18, §9410(a)(1) (2015 ***. Supp.) ( V. S. A.). The state law, by its terms, applies [**28] to health plans established by employers and regulated by the Employee Retirement Income Security Act of 1974 (ERISA), 88 Stat. 829, as amended, 29 U. S. C. §1001 et seq. The question [***5] before the Court is whether ERISA pre-empts the Vermont statute as it applies to ERISA plans.
Vermont requires certain public and private entities that provide and pay for [*941] health care services to report information to a state agency. The reported information is compiled into a database reflecting “all health care utilization, costs, and resources in [ Vermont], and health care utilization and costs for services provided to Vermont residents in another state.” 18 V. S. A. §9410(b). A database of this kind is sometimes called an all-payer claims database, for it requires submission of data from all health insurers and other entities that pay for health care services. Almost 20 States have or are implementing similar databases. See Brief for State of New York et al. as Amici Curiae 1, and n. 1.
Vermont’s law requires health insurers, health care providers, health care facilities, and governmental agencies to report any “information relating to health care costs, prices, quality, utilization, or resources required” by the state agency, including data relating to health insurance claims and enrollment. §9410(c)(3). Health insurers must submit claims data on members, subscribers, and policyholders. §9410(h). The Vermont [***6] law defines health insurer to include a “self-insured . . . health care benefit plan,” §9402(8), as well as “any third party administrator” and any “similar entity with claims data, eligibility data, provider files, and other information relating to health care provided to a Vermont resident.” §9410( j)(1)(B). The database must be made “available as a resource for insurers, employers, providers, purchasers of health care, and State agencies to continuously review health care utilization, expenditures, and performance in Vermont.” §9410(h)(3)(B).
Vermont law leaves to a state agency the responsibility to “establish the types of information to be filed under this section, and the time and place and the manner in which such information shall be filed.” §9410(d). The law has been implemented by a regulation creating the Vermont Healthcare Claims Uniform Reporting and Evaluation System. The regulation requires the submission of “medical claims data, pharmacy claims data, member eligibility data, provider data, and other information,” Reg. H-2008-01, Code of Vt. Rules 21-040-021, §4(D) (2016) (CVR), in accordance with specific formatting, coding, and other requirements, §5. Under the regulation, health insurers must report data about the health [***7] care services provided to Vermonters regardless of whether they are treated in Vermont or out-of-state and about non-Vermonters who are treated in Vermont. §4(D); see also §1. The agency at present does not collect data on denied claims, §5(A)(8), but the statute would allow it to do so.Read The Full CaseNot a Lexis Advance subscriber? Try it out for free.
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136 S. Ct. 936 *; 194 L. Ed. 2d 20 **; 2016 U.S. LEXIS 1612 ***; 84 U.S.L.W. 4101; 61 Employee Benefits Cas. (BNA) 2269; 26 Fla. L. Weekly Fed. S 1
ALFRED GOBEILLE, in his official capacity as CHAIR OF THE VERMONT GREEN MOUNTAIN CARE BOARD, Petitioner v. LIBERTY MUTUAL INSURANCE COMPANY
Notice: The LEXIS pagination of this document is subject to change pending release of the final published version.
Prior History: [***1] ON WRIT OF CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT
Liberty Mut. Ins. Co. v. Donegan, 746 F.3d 497, 2014 U.S. App. LEXIS 2088 (2d Cir. Vt., 2014)
Disposition: 746 F. 3d 497, affirmed.
pre-emption, pre-empts, data-collection, disclosure, Curiae, database, self-insured, quotation, Amici, fiduciary, coverage, entities, impermissible, recordkeeping, eligibility, Retirement, Patient, annual, exempt
Pensions & Benefits Law, ERISA, Federal Preemption, State Laws, Administration & Enforcement, Claim Procedures, Business & Corporate Compliance, Disclosure, Notice & Reporting, Benefits Information, Required Reports, Annual Reports, Summary Plan Descriptions, Required Reports, Disclosure & Reporting Exemptions, Regulators, Pensions & Benefits Law, Disclosure, Notice & Reporting, Recordkeeping Duties, Civil Litigation, Causes of Action, Failures to Respond, Criminal Charges & Defenses, Failures to Disclose & Report, Federal Preemption, Employee Retirement Income Security Act (ERISA), ERISA, Healthcare Law, Payment Systems, Insurance Coverage, Health Insurance, Constitutional Law, Supremacy Clause, Healthcare, Public Health & Welfare Law, Healthcare, Insurance Coverage