American Psychiatric Ass'n v. Anthem Health Plans, Inc., 821 F.3d 352

Background

Two psychiatrists (Drs. Savulak and Zanker) and three psychiatric associations sued four health insurers alleging the insurers reimburse mental-health and substance-use treatment at less favorable rates than medical/surgical care, violating the MHPAEA and ERISA and reducing patient access.
Plaintiffs sought declaratory and injunctive relief under MHPAEA/ERISA and state-law damages for contract/tort claims; associations sued on behalf of members and members’ patients; psychiatrists sued on behalf of themselves and patients (Dr. Savulak also alleged two patient assignments).
The district court dismissed: psychiatrists lacked a statutory cause of action under ERISA § 502(a)(3); Dr. Savulak’s patient assignments failed to show consideration in exchange for medical services; associations lacked Article III standing because their members lacked standing.
The district court also held insurers’ systemwide reimbursement-setting was a business decision, not an ERISA fiduciary act, and that § 502(a)(1)(B) would supply adequate relief if fiduciary claims were viable (court did not ultimately resolve the merits because of standing).
The Second Circuit affirmed on standing/cause-of-action grounds and therefore did not address the district court’s alternative failure-to-state-a-claim rulings.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether psychiatrists may sue under ERISA § 502(a)(3) on behalf of patients	Psychiatrists claim third‑party/prudential standing lets them assert patients’ ERISA/MHPAEA claims	Insurers argue § 502(a)(3) limits plaintiffs to participants, beneficiaries, or fiduciaries; third‑party standing cannot expand the statutory class	Held: No — psychiatrists lack a cause of action under § 502(a)(3); third‑party prudential standing cannot substitute for statutory authorization
Whether assignee Dr. Savulak has standing via patient assignments	Dr. Savulak says valid assignments give her ERISA standing to sue insurers	Insurers (and court) say assignments must be exchanged for healthcare services to confer standing to providers	Held: No — assignments lacked required consideration in exchange for medical services; Dr. Savulak lacks standing
Whether associations have Article III associational standing	Associations assert they can sue for members injured by parity violations	Insurers say members lack statutory cause of action and thus associations cannot show members would have standing	Held: No — associations fail Hunt requirements because their members lack a cause of action/standing
Whether insurers’ reimbursement-setting is an ERISA fiduciary act	Plaintiffs contend insurers’ coverage/reimbursement policies implicate ERISA duties	Insurers contend rate-setting is a corporate/business decision, not fiduciary plan administration	Court below: Business decision, not fiduciary act; Second Circuit affirmed on standing so did not decide merits

Key Cases Cited

Coalition for Parity, Inc. v. Sebelius, 709 F. Supp. 2d 10 (D.D.C. 2010) (background on MHPAEA’s purpose)
Lujan v. Defenders of Wildlife, 504 U.S. 555 (1992) (constitutional standing requirements)
Warth v. Seldin, 422 U.S. 490 (1975) (prudential standing and limits on third‑party assertions)
Bennett v. Spear, 520 U.S. 154 (1997) (distinction between Article III requirements and judicially self‑imposed prudential limits)
Lexmark Int’l, Inc. v. Static Control Components, Inc., 134 S. Ct. 1377 (2014) (statutory cause of action inquiry distinct from Article III standing)
Connecticut v. Physicians Health Servs. of Conn., 287 F.3d 110 (2d Cir. 2002) (ERISA § 502(a)(3) plaintiff‑class limitation)
Simon v. Gen. Elec. Co., 263 F.3d 176 (2d Cir. 2001) (narrow assignment exception: provider assignments must be exchanged for health care)
I.V. Servs. of Am., Inc. v. Trustees of Am. Consulting Eng’rs Council Ins. Tr. Fund, 136 F.3d 114 (2d Cir. 1998) (recognizing assignee standing in ERISA when properly exchanged)