REACH Air Medical Services LLC v. Kaiser Foundation Health Plan Inc.
M.D. Fla. → 11th Cir. · Updated
Summary
An air ambulance provider asked a federal court to vacate an IDR award, alleging Kaiser misstated its qualifying payment amount to the IDR entity. The Middle District of Florida dismissed the suit, and on November 19, 2025 the Eleventh Circuit affirmed in a published opinion, holding that NSA awards receive the FAA's narrow review and the complaint did not plead fraud, undue means or excess of authority.
Timeline of rulings
- 11th Cir.
Affirmed; the NSA incorporates the FAA's limited review, and the complaint did not plausibly allege fraud, undue means or that the IDR entity exceeded its powers.
Read the ruling - M.D. Fla.
Judgment entered after dismissal of the complaint without prejudice and dismissal of C2C with prejudice.
Why it matters
This is a vacatur case, not an enforcement case. Its published standard (160 F.4th 1110) is now the controlling test in the Eleventh Circuit and is cited by courts nationwide when payers or providers try to overturn IDR awards.
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Sources
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