Cedars Sinai Medical Center v. Mid-West National Life Insurance

ORDER GRANTING IN PART AND DENYING IN PART DEFENDANTS’ MOTION FOR SUMMARY JUDGMENT OF ALL CLAIMS

I.

Introduction

This action involves the medical insurance industry practice of “pre-certification,” whereby a medical insurer confirms to a health care provider that an insured’s coverage is in effect prior to treatment of the insured by the health care provider. Pre-certification normally consists of two parts: a verification of coverage and a certification that the proposed treatment is medically necessary.

Plaintiff Cedars-Sinai Medical Center (“Cedars”) brought this action for damages against defendants Mid-West National Life Ins. Co. of Tennessee (“Mid-West”) and Alliance for Affordable Services (“Alliance”) alleging nonpayment of claims for services provided to Mid-West’s insured, Daniel Bernheim (“Bernheim”) after Mid-West pre-certified coverage to Cedars. Cedars asserts claims for breach of oral contract, fraud and deceit, negligent misrepresentation, estoppel, and quantum me-ruit in its complaint. Jurisdiction is based upon diversity of citizenship, 28 U.S.C. § 1332 .

Pending before the court are Mid-West’s and Alliance’s motions for summary judgment on all claims.…