UnitedHealthcare of Pennsylvania, Inc. v. NorthStar Anesthesia of Pennsylvania, LLC
E.D. Pa. · Updated
Summary
UnitedHealthcare sought declarations and an injunction after an anesthesia provider took a Medicaid patient's claim, ineligible for federal IDR, through the process. On April 28, 2026, Judge Kearney dismissed the common-law fraud claim without prejudice for lack of subject-matter jurisdiction, noting the insurer had not sought vacatur under the NSA's FAA-based review.
Timeline of rulings
- E.D. Pa.
Complaint dismissed without prejudice for lack of subject-matter jurisdiction; fraud claim raised no substantial federal question, and the insurer did not seek vacatur of the IDR award.
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Why it matters
The decision holds that a payer cannot bring a state-law fraud claim into federal court merely because it turns on IDR eligibility, steering payers to the statute's limited vacatur route or to the Departments.
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