Quality Infusion Care, Inc. v. Health Care Serv. Corp., No. 09-20188

Action for Health Insurance Overpayments

In Quality Infusion Care, Inc. v. Health Care Serv. Corp., No. 09-20188, an action by a non-contracted healthcare provider to defendant health insurance policyholders, the court affirmed summary judgment for defendant where defendant had a contractual right under all three plans to privately deduct overpayments it had previously made to plaintiff from subsequent claims it was obligated to pay plaintiff.

As the court wrote:  "This case presents a narrow legal dispute between a healthcare provider, Quality Infusion Care, Inc. ("QIC"), and an insurance company, Healthcare Service Corp., d/b/a Blue Cross and Blue Shield of Texas ("BCBS").  BCBS overpaid QIC for certain patient claims and then set off the overpayments by underpaying subsequent patient claims, without regard to whether the subsequent claim was from the same patient or under the same insurance plan."

Related Resources

• Read the Fifth Circuit's Decision in Quality Infusion Care, Inc. v. Health Care Serv. Corp., No. 09-20188