PHI Health, LLC v. Health Care Service Corp.
N.D. Ill. → 7th Cir. · Updated
Summary
An air ambulance provider sued HCSC over overdue IDR payment awards under the NSA, the FAA, ERISA and Illinois law. On August 5, 2026, Judge Kennelly dismissed, holding the NSA creates no implied private right of action and the FAA cannot be used to confirm IDR awards. Judgment entered August 18; PHI appealed on August 19, and the Seventh Circuit consolidated it with four related SpecialtyCare and PHI appeals against HCSC.
Timeline of rulings
- 7th Cir.
Appeal consolidated for briefing and disposition with SpecialtyCare, Inc. v. Health Care Service Corp. (Nos. 26-2269 et al.); appellee brief due Oct. 9, 2026.
Read the ruling - N.D. Ill.
Order of dismissal and judgment entered.
- N.D. Ill.
Motion to dismiss first amended complaint granted; no implied private right of action under the NSA and no FAA or Illinois arbitration-act confirmation of IDR awards.
Read the ruling
Why it matters
The Seventh Circuit appeal could become the third circuit to decide the question; the district court expressly rejected the contrary District of Maryland and District of Connecticut decisions.
Related insights
Sources
General information only, not legal advice. Verdict Consulting Group is not a law firm.