San Francisco Ladies’ Protection and Relief Society v. RPM Billing, LLC, et al.

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO LADIES’ Case No. 25-cv-06090-RFL

PROTECTION AND RELIEF SOCIETY,

Plaintiff, ORDER GRANTING IN PART AND

DENYING IN PART MOTION TO

v. DISMISS

RPM BILLING, LLC, et al., Dkt. No. 12 Defendants.

Plaintiff, San Francisco Ladies’ Protection and Relief Society d/b/a Heritage on the Marina (“Heritage”), brings this action against RPM Billing, LLC, Kovo+Holdings, LLC, KovoRCM,1 and unnamed Does. (Dkt. No. 11-1 (“Compl.”).) Heritage alleges that it contracted with Defendants to be its exclusive billing agent to seek reimbursement for skilled nursing care provided by Heritage to Medicare beneficiaries. (Id. ¶¶ 3–5, 14, 16.) According to the Complaint, Heritage has not received expected Medicare reimbursement for approximately $400,000 in services rendered in 2022 and early 2023. (Id. ¶¶ 21, 41.) Heritage alleges that it repeatedly informed Defendants of the outstanding claims, but Defendants failed to submit or re- submit the claims, and intentionally misrepresented the status of the outstanding claims to Heritage. (Id. ¶¶ 37–38.) Heritage brings…