Fairfield County Medical Association V. United Healthcare .

2y ago
34 Views
2 Downloads
3.76 MB
48 Pages
Last View : 16d ago
Last Download : 4m ago
Upload by : Elisha Lemon
Transcription

Case: 13-4608Document: 119Page: 112/30/2013112380448-o.'Uníteb á5tatts' QCourt of rapeals'for theá5ttonb QCírcuítTHE FAIRFIELD COUNTY MEDICAL ASSOCIATION ANDHARTFORD COUNTY MEDICAL ASSOCIATION, INC.Plaintifs-Appellees,v.UNITED HEALTHCARE OF NEW ENGLAND, UNITED HEALTHCARE INSURANCECOMPANY, INC., UNITED HEALTHCARE SERVICES, INC.,AND UNITEDHEALTH GROUP, INC.,Defendants-Appellants.On Appeal from the United States District Courtfor the District of ConnecticutBRIEF AMICI CURIAE OF AMICI ASSOCIATIONS IN SUPPORTOF PLAINTIFFS-APPELLEES AND IN SUPPORT OF AFFIRMANCE OFTHE DISTRICT COURT'S PRELIMINARY INJUNCTIONWHATLEY KALLAS, LLPEdith M. KallasJoe R. Whatley, Jr.I1ze C. Thielmann380 Madison Avenue, nrd FloorNew York, New York 10017(212) 447-7060Attorneys for Amici Associationslisted on inside(Additional counselfront cover.)

Case: 13-4608Document: 119Page: 212/30/2013112380448Additional counsel for AmiciAssociations:Deborah J. WinegardWhatley Kallas, LLPi 068 Virginia Avenue NEAtlanta, Georgia 30306(404) 607-8222Catherine HansonWhatley Kallas, LLP) Sansome Street, 35th FloorSan Francisco, California 94 i 04(415) 906-3876

Case: 13-4608Document: 119Page: 312/30/2013112380448RULE 26.1 CORPORATE DISCLOSURE STATEMENTPursuant to Rule 26.1 of the Federal Rules of Appellate Procedure, amicicuriae (listed in footnote 2 below) certify that they are all non-profit corporationsthat do not have any parent corporations, and that no publicly held corporationsown 10% or more of any of their stock.

Case: 13-4608Document: 119Page: 412/30/2013112380448TABLE OF CONTENTSSTATEMENT OF INTEREST OF THE AMICI CURIAE .2SUMMARY OF ARGUMENT .4ARGUMENT.6i. THE PLAINTIFF ASSOCIATIONS' MEMBERS WILL BEIRRP ARABL Y HARMED IN THE ABSENCE OF ANINJUNCTION .6II. THE BALANCE OF THE HARDSHIPS TILTS IN FAVOROF PRELIMINARY INJUNCTIVE RELIEF .11II THE PLAINTIFF ASSOCIATIONS HAVE STANDING .14A. The Plaintiff Associations' Litigation on Their Members'Behalf Does Not Create a Conflict ofInterest.15the PlaintiffB. Participation ofIndividual Members ofAssociations Is Not Required. . . .19CONCLUSION .22CERTIFICATE OF COMPLIANCE.2411

Case: 13-4608Document: 119Page: 512/30/2013112380448TABLE OF AUTHORITIESCASESAgency for Int 'I Dev. v. Allance for Open Soc y Int 'I, Inc.,133 S. Ct. 2321 (U.S. 2013) .19Allance for Open Soc y Int 'I,651 F .3d at 229. . . . . . . . . . .21AMA v. United Healthcare Corp.,2002 U.S. Dist. LEX1S 20309 (S.D.N.Y. Oct. 23, 2002) .20AMA v. United Healthcare Corp.,2007 U.S. Dist. LEXIS 44196 (S.D.N.Y. June 18,2007).20AMA v. United Healthcare Corp.,588 F. Supp. 2d 432 (S.D.N.Y. 2008).20North Dakota v. Otter Tail Power Co.,611 F.2d 684 (8th Cir. 1979) .17Associated Gen. Contractors ofBarron v. Vision Servo Plan,575 F. Supp, 2d. 825 (N.D. Ohio 2008) .7New York Inc.,610 F.3d 1296 (11th Cir. 2010).19Borrero v. United Healthcare ofConnecticut Ass 'n of Health Care Facilities, Inc. v. Worrell,199 Conn. 609 (1986) . . . . . .19Hunt v. Wash. St. Apple Adver. Comm 'n,432 U.S. 333 (1977) .5, 14Md. Highways Contractors Asso. v. Maryland,933 F.2d 1246 (4th Cir. 1991 ).17Nat'I Collegiate Athletic Ass 'n v. Califano,622 F.2d 1382 (10th Cir. 1980).18Open Soc y Int 'I, Inc. v. United States Agency for Int 'I Dev.,651 F.3d 218 (2d Cir. 2011).19Pa. Chiropractic Ass 'n v. Blue Cross Blues Shield Ass 'n,713 F. Supp. 2d 734 (N.D. Il 2010).21ii

Case: 13-4608Document: 119Page: 612/30/2013112380448Polaroid Corp. v. Disney,862 F.2d 987 (3d Cir. 1988) .17Chicago,76 F.3d 856 (7th Cir. 1996) .17Retired Chi. Police Asso. v. City ofRoudachevski v. All-Amer. Care Ctrs., Inc.,648 F.3d 701 (8th Cir. 2011).7Schisler v. Heckler,574 F. Supp. 1538 (W.D.N.Y. 1983) .7IV

Case: 13-4608Document: 119Page: 712/30/2013112380448United HealthCare ("United"), the nation's largest Medicare AdvantageInsurer, has notified thousands of members of the Plaintiff-Appellee associations,Fairfield County Medical Association and Hartford County Medical Association,Inc. (together, the "Plaintiff Associations" or "Plaintiffs"), that they are beingterminated from United's Medicare Advantage ("MA") Network, disruptingphysician-patient relationships and patient treatment, harming the public health ofthe elderly and disabled citizens of Connecticut, and harming the physicians whoare members of the Plaintiff Associations. The preliminary injunction entered bythe District Court below (the "PI Order") temporarily keeps in place thearrangements between United and physicians that have functioned for years. WhileUnited's actions will cause the Plaintiff Associations' members irreparable harm,there is no possible irreparable harm to United from the preliminary injunction.Moreover, contrary to United's argument, the Plaintiff Associations havestanding to assert the claims herein on behalf of their members. Thus, the AmiciAssociations! respectfully submit that the Court should affirm the District Court's1 The Amici Associations are listed in footnote 2 below, and their individualinterests in this case are identified in the Motion for Leave To File Brief AmiciPlaintiffs-Appellees and In Support ofAffirmance of the District Court's Preliminary Injunction. No party or party'scounsel has authored this brief in whole or in part or contributed money intendedCuriae of Amici Associations In Support Ofto fund preparing or submitting this brief. No person other than the AmiciAssociations, their members, or their counsel have contributed money intended tofund preparing or submitting this brief.1

Case: 13-4608PIDocument: 119Page: 812/30/2013112380448Order.AMICI CURIAESTATEMENT OF INTEREST OF THEThe Amici Associations include thirty-three national, state, county, andspecialty medical associations,2 many of whose members participate in United'sMA network, and two national physicians' advocacy organizations, whichadvocate for physicians' interests on such issues as involved in this case.2 As set forth in the Motion for Leave to File Brief Amici Curiae in Support ofPlaintiffs-Appellees and in Support of Affirmance of the District Court'sPreliminary Injunction, the thirty-three national, state, county and specialty AmiciAssociations are: Connecticut State Medical Society, American MedicalAssociation, Inc., Connecticut Chapter of the American College of SurgeonsProfessional Association, Connecticut Academy of Family Physicians, ConnecticutInfectious Disease Society, Connecticut Orthopaedic Society, ConnecticutPsychiatric Society, Inc., Connecticut Chapter of the American Academy ofPediatrics, Connecticut Council of Child and Adolescent Psychiatry, MiddlesexCounty Medical Association, New Haven County Medical Association, NewLondon County Medical Association, Tolland County Medical Association,Waterbury Medical Association, Windham County Medical Association,California Medical Association, Florida Medical Association, Medical Associationof Georgia, Indiana State Medical Association, Medical Association of NewJersey, Medical Association of the State of New York, North Carolina MedicalSociety, Ohio State Medical Association, Tennessee Medical Association, TexasMedical Association, American Academy of Dermatology Association, AmericanSociety of Interventional Pain Physicians, American Academy of FamilyPhysicians, New Jersey Society of Gastroenterology and Endoscopy, New JerseyChapter of the American College of Cardiology, the New Jersey RheumatologyAssociation, the New Jersey Academy of Otolaryngology - Head & Neck Surgeryand the New Jersey Academy of Facial Plastic Surgery. The two nationalphysicians' advocacy organizations are the Litigation Center of the AmericanMedical Association and State Medical Societies and the Physicians AdvocacyInstitute, Inc.2

Case: 13-4608Document: 119Page: 912/30/2013112380448As set forth in detail in the Motion for Leave to File Brief Amici Curiae inSupport of Plaintiffs-Appellees and in Support of Affrmation of the DistrictCourt's Preliminary Injunction, many of the Amici Associations have memberswho are also members of the Plaintiff Medical Associations and who have beendirectly affected by United's proposed terminations in Connecticut. With theexception of the Medical Association of Georgia, all of the Amici Associationshave members who are among the tens of thousands of physicians terminated fromUnited's MA Networks nationwide, and members of the Medical Association ofGeorgia fear that similar terminations could come soon to that state.The amici national, state, county and specialty medical associations alldevote a significant amount of resources to assisting doctors with contractualissues that arise in relationships with health insurance companies, such as theissues involved in this case. The two amici national physicians' advocacyorganizations regularly advocate for physicians on issues involving physicians'relationships with health insurers. As a result, the amici have developed extensiveknowledge about the issues in this case and how United's planned terminations ofphysicians from its MA network would impact physicians, physician-patientrelationships, patients, and the healthcare consuming public at large. As such, theamici would offer insights based on their experience to aid the Court in assessingthe amici haveUnited's arguments for lifting the injunction. In addition, several of3

Case: 13-4608Document: 119Page: 1012/30/2013112380448extensive expenence and knowledge regarding the ability of associations torepresent the interest of their members in court, and therefore are well-positionedto address United's flawed arguments that the Plaintiff-Appellee medicalassociations do not have standing.SUMMARY OF ARGUMENTUnited asks this Court to lift the preliminary injunction entered by theDistrict Court enjoining United from implementing the termination of more than2,000 physicians from United's MA network, enjoining United from notifying itsMA network customers that certain participating physicians will be terminatedfrom the MA network as of February i, 20 i 4, and compelling United to reinstate,advertise, and market the affected physicians in their 2014 directories for the MAnetwork. (Joint Appendix ("J.A.") 814.)United argues, among other things, that the District Court erred in grantingthe preliminary injunction because neither the Plaintiff Associations nor theirphysician members will suffer irreparable harm absent a preliminary injunction,and because the balance of hardships tilts against preliminary injunctive relief.Both arguments are wrong. Over years of serving the interests of those in themedical profession and their patients, especially in the era of managed care andconstant changes in the health insurance industry, the amici have developedextensive knowledge about the effects that misconduct by insurers such as that4

Case: 13-4608Document: 119Page: 1112/30/2013112380448which the Plaintiff Associations challenge here has on the doctor-patientrelationship, on doctors' ability to provide continuity of care, and on the healthcareconsuming public in general. United's conduct, if not enjoined, would havedevastating effects in all of these categories, as will be discussed.United also argues that the District Court also erred in finding that theAssociation Plaintiffs have standing to sue on behalf of their members. That issimply incorrect. Plaintiffs have satisfied all of the requirements of Hunt v. Wash.St. Apple Adver. Comm 'n, 432 U.S. 333, 343 (1977), in which the U.S. SupremeCourt set forth the circumstances under which an association may sue on itsmembers' behalf. United's attempt to fabricate a "conflict of interest" between themembers of the Plaintiff Associations who have been terminated by United andthose who have not fails. The litigation brought by the Plaintiff Associationsbenefits all oftheir physician members, and creates no such conflict.Contrary to United's second argument against associational standing, theclaims here do not require the Plaintiff Associations' members to participateextensively in the litigation. Medical societies such as the Plaintiff Associationsand amici are regularly found to have standing to sue on behalf of their membersunder circumstances similar to those presented here. Contractual obligations to gothrough an individual appeals process and individual arbitration do not mean thatindividual participation is required in the instant litigation, which ultimately seeks5

Case: 13-4608Document: 119Page: 1212/30/2013112380448only to preserve the rights of physicians to undergo those processes pursuant to theterms ofthe provisions contained in United's standard-form participating physiciancontracts.ARGUMENTi. THE PLAINTIFF ASSOCIATIONS' MEMBERS WILL BEIRREPARABLY HARMED IN THE ABSENCE OF AN INJUNCTIONThe Plaintiff Associations' members would be irreparably harmed in theabsence of an injunction because United would proceed with its plannedterminations of physicians from its MA network on February 1, 2014, therebyinterfering with the Plaintiff Associations' members' physician-patientrelationships.3 Lifting the injunction would necessarily force affected Medicarepatients - the elderly and disabled, who disproportionately tend to suffer fromchronic and often life-threatening conditions whose treatment is enhanced bycontinuing care - to find new physicians to meet their medical needs.In granting the injunction, the District Court found that:the Associations' members who are subject to the termination noticeswill suffer (i) disruption of their relationships with the MedicareAdvantage patients. . . . The disruption of physician-patientrelationships results from the high cost of medical care in the countryand the structure of health insurance reimbursement plans thatdistinguish between in-network and out-of-network service providers.3 While United also argues that the Plaintiff Associations would not sufferirreparable harm, the correct inquiry is whether their members would suffer suchharm, as the Plaintiff Associations are not suing in their own behalf, but solely ontheir members' behalf.6

Case: 13-4608Document: 119Page: 1312/30/2013112380448The terminated providers' patients could continue their existingrelationships with the affected physicians only if they are able andwillng to pay substantially greater sums to obtain those medicalservices. (l.A. 809-10.)In so ruling, the Court noted that although the Second Circuit has notdirectly ruled on whether the disruption of the physician-patient relationshipconstitutes irreparable harm, "several district and circuit courts have found thatdisruption of the physician-patient relationship can cause irreparable harm thatjustifies issuing preliminary injunctive relief, particularly when the patient belongsto a vulnerable class or may have a deep trust relationship with the physicianbecause ofthe serious nature ofthe patient's illness or medical needs." (l.A. 808-09 (citing to Schisler v. Heckler, 574 F. Supp. 1538, 1552 - 53 (W.D.N.Y. 1983),Roudachevski v. All-Amer. Care Ctrs., Inc., 648 F.3d 701, 706-707 (8th Cir. 2011),and Barron v. Vision Servo Plan, 575 F. Supp, 2d. 825, 835-36 (N.D. Ohio 2008).)The Court's findings were supported by substantial evidence in the recordregarding the impact of disrupting the physician-patient relationships betweenPlaintiff Association members slated for termination and their patients, particularlyin light of these patients' serious medical conditions. As stated by William A.Hunt, M.D., a nephrologist: "(TJhe long-standing physician-patient relationship isbeing threatened. .Continuity of care is crucial in managing kidney ilnessesbecause of its progressive nature and its association with numerous multi-systemcomplications. Physicians who know and understand the particular nuances of7

Case: 13-4608Document: 119Page: 1412/30/2013112380448their elderly patients, especially those with substantial medical histories andrecords, often rely on their familiarity and unique experience with each individualpatient, in order to fashion and manage an appropriate plan of treatment." (l.A.224.)In arguing that the Plaintiff Associations' members will not be irreparablyharmed by the lifting of the preliminary injunction, United totally ignored thisfinding by the District Court, which was amply supported by the record below.Rather, United boldly states that "contrar to District Court's conclusion, theaffected providers will not 'suffer a disruption of their relationships with their("App. Br.") at 30 (quoting fromMedicare Advantage patients'" (Appellants' BrieflA. 808)), but then makes no effort to explain how the disruption of physicianpatient relationships can possibly be avoided when thousands of physicians areterminated from its MA network. Instead, United mischaracterizes the DistrictCourt's concern as one of "patient confusion during the open-enrollment period."(App. Br. at 30.) However, the unambiguous language from the District Court'sopinion makes it clear that the finding of irreparable harm was based on the factthat patients generally have to pay more for out-of-network care, and that thesefinancial imperatives would prevent patients from continued treatment by theircurrent physicians. As the declarations filed in the record below make clear, this isparticularly problematic for the elderly and disabled patients enrolled in MA plans,8

Case: 13-4608Document: 119Page: 1512/30/2013112380448who tend to suffer from chronic and often life-threatening conditions for whichcontinuity of treatment is criticaL. (See generally l.A. 220-25; l.A. 200-19; lA.253-73; lA 241-52.)The likely reason for United's utter failure to address the issue of disruptionof physician-patient relationships is that it undermines United's argument thatthere is no irreparable harm because "money damages would make an aggrievedprovider whole." (App. Br. at 30.) Clearly, no amount of money damages couldcompensate for the disruption of the many physician-patient relationships that wilinevitably occur ifthe injunction is lifted.United further argues that lifting the injunction would not harm the PlaintiffAssociations' members because there is suffcient time for these physicians toappeal and arbitrate the terminations before the February 1,2014 termination date.light of(Id. at 29.) That assertion is speculative at best, particularly inthe fact thatFebruary 1, 2014 is less than six weeks away and in view of the interveningholidays. Moreover, because United has been terminating thousands of physiciansfrom its MA networks across the country (hence, the interest of amici), United willpresumably be arbitrating these cases in multiple venues in this short interim.Consequently, it is unlikely that the arbitrations for all the physicians covered bythe injunction will be concluded by Februar 1,2014.9

Case: 13-4608Document: 119Page: 1612/30/2013112380448Lifting the injunction would compound the irreparable harm to anyassociation member whose arbitration was successfully concluded after Februaryi, 2014, because by that time the member's patients likely will have sought carewith physicians whose in-network status was not disrupted, and will be unlikely toswitch back after the physician is reinstated. In finding irreparable harm sufficientto warrant a preliminary injunction halting termination of an optometrist from aninsurer's network in the Barron v. Vision Servo Plan case cited by the DistrictCourt, the Northern District of Ohio stated: "Out of network benefits, however,are less than 'in network' benefits. It is unlikely that many patients would see anon-network optometrist when they could see a network optometrist forsignificantly less. .If (the optometrist) were to prevail on his claim., it isunlikely that many of his former patients would return to him once he rejoined thenetwork. In the meantime, most patients would have found other providers." 575F. Supp. 2d 825, 836.This problem is particularly acute in the context of the MA Network.Medicare beneficiaries in the MA network pay a supplemental MedicareAdvantage fee in addition to their Medicare premiums, and thus expect not to paymore for their care. While Medicare FFS patients are aware that they must paycopayments and coinsurance after their deductible is met, MA plan members havea general expectation that everyhing is covered (which is why they have10

Case: 13-4608Document: 119Page: 1712/30/2013112380448purchased an MA plan in the first place, because they are risk-adverse and want allof their care to be covered, and thus pay more up-front). Therefore, rather thancontinuing to see their existing physicians and paying even more because thosephysicians are no longer in-network, many if not most MA plan members willchoose to find another physician who is in-network. In many cases there is nocoverage for any out-of-network care in the MA plan descriptions, which makes itthat much more likely that patients will seek care elsewhere when a physician isterminated from the MA network.There can be no doubt that United's February 1, 2014 terminations willdisrupt longstanding physician-patient relationships for elderly and disabledpatients whose care is enhanced by continuity of care. In so doing, United hasbreached its obligation under its MA contract to uphold and protect enrollee rights.In response, United can only point to physicians' rights to arbitrate theterminations. In order to ensure that these rights are real, and to allow for thecontinuation of physician-patient relationships for those physicians who prevail atarbitration, the injunction must be maintained. Otherwise, the physicians and theirrelationships with their patients will suffer irreparable harm.II. THE BALANCE OF THE HARDSHIPS TILTS IN FAVOR OFPRELIMINARY INJUNCTIVE RELIEFUnited attempts to argue that the injunction does not maintain the status quobecause keeping the terminated physicians in its MA network imposes certaini i

Case: 13-4608Document: 119Page: 1812/30/2013112380448obligations on United. In support of this argument, United only lists administrativetasks and processes such as online and printed provider directories, customer carescripts and its ongoing appeals processes. (App. Br. at 32.)However, theinjunction does maintain the status quo with respect to the status of the providerswithin the MA network, allowing the physician-patient relationships to continuepending the outcome ofthis litigation, and ensuring that the arbitrations proceed inan orderly fashion. United's administrative concerns are greatly outweighed by thevery real harm that would be caused by the disruption of the physician-patientrelationships and the harm to these patients' care which would result without theprotection of the injunction.In addition, United argues that the balance of hardships weighs in its favorbecause "the District Court's order deprives United of its contractual right to builda competitive, sustainable network that can better achieve improved populationhealth outcomes, improved patients' experience with care, and lower per-capitahealth care costs" and "intrudes on CMS' authority to regulate United's networkdecisions." (App. Br. at 31 (emphasis added).)Despite United's efforts to cast its contractual rights as improving healthoutcomes, its self-serving statements must be viewed in the context of its brief, inwhich United dropped any effort to argue that the public interest favors itsposition. It cannot make any such argument because the public interest lies in12

Case: 13-4608Document: 119Page: 1912/30/2013112380448ensunng that United's MA network has suffcient pnmary care and specialtyphysicians to serve its Connecticut MA patients and in ensuring that there is nodisruption in care for MA members, concerns raised by Connecticut AttorneyGeneral George Jepson in a November 6, 2013 letter to the U.S. Department ofHealth and Human Services (Exhibit A hereto), and in the letters of amicus theConnecticut State Medical Society in two letters to CMS, dated October 23,2013and December 2,2013. (Exhibits Band C hereto).United's argument regarding a supposed intrusion on CMS' authority fallsflat in the face of evidence that CMS has not scrutinized the impact of United'snetwork terminations on various patient populations in Connecticut. As stated inCMS's December 6, 2013 letter to Mr. Jepson: "Our time/distance/numberstandards do not, however, take into account the special needs of the disabled,elderly, low income, without personal transportation, and non-English speakingmembers." (Exhibit D hereto.) In response, Mr. Jepson issued a statement saying"I am deeply disappointed by CMS's response and its continuing refusal to takeconcrete action to protect thousands of patients affected by United's terminationsofConnecticut physicians." (Exhibit E hereto.)In fact, by emphasizing that the terminated physicians will remain in itsother networks, United has conceded that the terminations are not related to thequality of care, but rather are tied to its costs to providing care to its MA members.13

Case: 13-4608Document: 119Page: 2012/30/2013112380448The letter to terminated providers specifically states: "Please note that yourAgreement shall remain in full force and effect for all other networks not specifiedin this Agreement and we are pleased to have you remain in those networks." (I.A.42.)Thus, the public interest is served by maintaining the injunction in effect,allowing Connecticut's MA members to continue seeking care from theirphysicians - the Plaintiff Associations' members affected by United's massterminations - pending the outcome of this litigation. When the public interest isweighed against United's administrative tasks and its efforts to cut costs, it is clearthat the balance of the interests tilts decidedly in favor of maintaining theinjunction.II. THE PLAINTIFF ASSOCIATIONS HAVE STANDINGUnited also argues that the District Court erred in finding that the PlaintiffAssociations had standing to assert claims on their members' behalf. That issimply incorrect. Under Hunt v. Wash. St. Apple Adver. Comm 'n, 432 U.S. 333(1977), the Plaintiff Associations have standing to sue on their members' behalf if:(I) their members, "or anyone a/them," would have standing to sue in their ownright; (2) the interests the Plaintiff Associations seek to protect are germane to thePlaintiff Associations' organizational purpose; and (3) neither the claim assertednor the relief requested requires the participation of the individual members in the14

Case: 13-4608Document: 119Page: 2112/30/2013112380448lawsuit. Id. at 342-43 (emphasis added). United's argument that the PlaintiffAssociations fail to satisfy prongs (2) and (3) above must faiL.A. The Plaintiff Associations' Litigation on Their Members' BehalfDoes Not Create a Conflct of InterestUnited argues that the Plaintiff Associations' claims "stand to benefit only arelative handful of their members," and that "(aJny such benefit will come at theexpense of the large number of Association members who remain in United'sMedicare Advantage Network." (App. Br. at 20.) Thus, United posits, there is aconflict of interest here that defeats associational standing under either the secondor third prong of the Hunt test. (Id. at 2 i.) United is wrong.United's argument is premised on the false notion that "United's removal ofa small number of providers from its network will benefit every remainingprovider in the network because those remaining providers will face lesscompetition from others in the same network." (Id.) To the contrary: First, as isalleged in the underlying complaint, "in many cases, the Medical Associations'members are the only providers furnishing these services in their geographic area."(I.A. 22, ir 52.) Thus, the notion that non-terminated members stand to gain by areduction in "competition" is not consistent with the reality of many communities.Second, United's improper termination of providers from the MA network in areaswhere there are other providers available would negatively affect those otherproviders, who would have to bear the burden of serving Medicare patie

Society of Interventional Pain Physicians, American Academy of Family Physicians, New Jersey Society of Gastroenterology and Endoscopy, New Jersey Chapter of the American College of Cardiology, the New Jersey Rheumatology Association, the New Jersey Academy of Otolaryngology - Head & Neck Surgery and the New Jersey Academy of Facial Plastic .

Related Documents:

Erie St Mary Erie St Peter Erie Townsend North Community School Erie Vermilion Local Fairfield Amanda-Clearcreek Local Fairfield Berne Union Local Fairfield Bloom-Carroll Local Fairfield Fairfield Christian Academy Fairfield Fairfield County Board of DD Fairfield Fairfield County Esc .

1994 in Cary, Wake, North Carolina Mary Fredericks b: 05 Jul 1910 in Shelton, Fairfield, Connecticut; Fairfield County, d: 18 Dec 1957 in Norwalk, Fairfield, Connecticut; Fairfield County, m: 12 Apr 1937 in

The Mall at Fairfield Commons is one of the premier retail centers in Ohio’s Dayton-Springfield metropolitan area. Located in the suburb of Beavercreek, it sits on the heavily traveled North Fairfield Road, just 1 mile south of I-675. The Mall at Fairfield Commons has convenient access to Interstates 70 and 675, as well as to State Route 35.

Office: Institutional Research Mailing Address: 1073 North Benson Road City/State/Zip/Country: Fairfield, CT 06824 USA Phone: 203-254-4000 Fax: 203-254-4291 E-mail Address: aboczer@fairfield.edu x Yes No If yes, please provide the URL of the corresponding Web page: A0A A1 Address Information Name of College/University: Fairfield University

FAIRFIELD UNIVERSITY UNDERGRADUATE OVERVIEW Founded in 1942, Fairfield University is a Jesuit and Catholic University that is rooted in one of the world's oldest intellectual and spiritual traditions. Fairfield prepares students for leadership and service in a constantly changing world through broad intellectual inquiry, the pursuit

Fairfield College Preparatory School, and is available on our P website: www.fairfieldprep.org. Editorial offices are located in: Fairfield College Preparatory School Development and Alumni Office Xavier Hall 112 Fairfield, CT 06824-5157 (203) 254-4237 letteRs to the eDitoR: Send to above address or by email to: cadams@fairfieldprep.org

JAMES .AND GEORGE ASHFORD JRq, OF FAIRFIELD COUNTY SOUTH CAROLINA BY CHARLIE RABB ASHFORD SRe 208 N Mont.gomery Stn Starkvilles Mississippi 1956 . TO MY MOTHER AND TO THE MEMORY OF MY FATHER . PREFACE The challenge to make this study came after learning my great granruather, John Rabb Ashford, came to Mississippi, from Fairfield .

Chatham County Chattahoochee County Chattooga County Cherokee County Clarke County Clay County Clayton County Cobb County Coffee County Colquitt County Columbia County Cook County Coweta County Crisp County 320 6 2 1 2 4 1 10 12 6 4 43 1 1 3 2 4 11 4 1 5 6 6 5 60 1 1 7 22 1 58 51 7 3 8 4 6 5 19.80% .37% .12% .06% .12% .25% .06% .62% .74% .37% .