Stone v. UnitedHealthcare Ins. Co.
Stone v. UnitedHealthcare Ins. Co. (U.S. Court of Appeals, Ninth Circuit, November 9, 2020): An insurance coverage denial for eating disorder treatment based solely on an ERISA plan’s exclusion of coverage for out-of-state treatment does not violate the federal Mental Health Parity and Addiction Equity Act or California’s Mental Health Parity Act since the exclusion applies equally to mental and physical illnesses. The Ninth Circuit explained that (1) both acts require health plans to provide equal coverage for physical and mental illnesses; and (2) coverage denials were based solely on out-of-state treatment exclusions, which apply equally to either type of illnesses. Aware of the exclusion, an insured sent her daughter to an out-of-state residential treatment program for anorexia nervosa treatment. The court therefore found no violation of either the federal or state act. Read the full decision here.