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Payer v. providerDismissed

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

  1. 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.

    Read the ruling

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.

Sources

  1. UnitedHealthcare of Pennsylvania v. NorthStar Anesthesia, Memorandum (E.D. Pa. Apr. 28, 2026)
  2. O'Neill Institute tracker — UnitedHealthcare of Pennsylvania v. NorthStar Anesthesia

General information only, not legal advice. Verdict Consulting Group is not a law firm.