Healing at Hidden River, LLC v. Aetna Life Ins. Co.
| Court | New Jersey Superior Court |
| Writing for the Court | HON. STEPHEN L. PETRILLO, JUDGE |
| Docket Number | ESX-L-2381-25 |
| Decision Date | 21 November 2025 |
| Citation | Healing at Hidden River, LLC v. Aetna Life Ins. Co., ESX-L-2381-25 (N.J. Super. Nov 21, 2025) |
| Parties | HEALING AT HIDDEN RIVER, LLC, Plaintiff, v. AETNA LIFE INS. CO., d/b/a Aetna, a/k/a Global Claims Services, et al. Defendants. |
THIS MATTER having been opened to the Court by Robinson & Cole LLP, and Calcagni & Kanefsky, LLP, attorneys for Defendants, Aetna Life Insurance Company, Meritain Health, Inc., Aetna Health, Inc., Aetna Health Management LLC, Global Claims Services, Aetna, Inc., Jordache Enterprises, Inc., NAPA Management Services Corporation (improperly identified as "North American Partners in Anesthesia Management Services Corp."), PNC Financial Services Group, Inc., A. Duie Pyle, Inc., MetLife, Princeton University, Atlantic Health System Inc., CitiGroup, TriNet Group, Inc., Saint Peter's Healthcare System, Trainee LLC., Bristol-Myers Squibb Co., Johnson &Johnson, and University of New Haven, (collectively "defendants") for an Order dismissing the claims asserted against defendants in plaintiff Healing at Hidden River, LLC's Complaint, and the court having considered all the moving papers, and any opposition thereto, and good cause having been shown;
IT IS on this 21st day of November 2025;
ORDERED that the defendants' Motion to Dismiss is hereby GRANTED without prejudice in so far as it relates to claims based on a theory of agency, Count 5 in part (negligence), and it is further ORDERED that the motion is DENIED as it relates to claims based on a theory of direct liability, Counts 1-4, Count 5 (negligent misrepresentation), and Counts 7-8; and it is further
ORDERED that a copy of this Order shall be served in accordance with R. 1:5-1(a).
OPINIONThis matter comes before the court by way of a pre-answer motion to dismiss for failure to state a claim filed by Aetna Life Insurance, Co., Aetna Life Insurance Company, Meritain Health, Inc., Aetna Health, Inc., Aetna Health Management, LLC, Global Claims Services, Aetna, Inc. (collectively "Aetna"), Jordache Enterprises, Inc., NAPA Management Services Corporation (also identified as "North American Partners in Anesthesia Management Services Corp."), PNC Financial Services Group, Inc. A. Duie Pyle, Inc., MetLife, Princeton University, Atlantic Health System Inc., CitiGroup, TriNet Group, Inc., Saint Peter's Healthcare System, and Tramec, LLC (all are collectively "defendants"). The Vanguard Group is also a defendant in this action but separately moved to dismiss. Their motion was decided on October 8, 2025.
After careful review of the parties' submissions and the controlling legal precedents in New Jersey, the defendants' motion is hereby GRANTED in part and DENIED in part.
At this stage of the litigation all factual statements are drawn from the complaint and assumed to be true.[1]
This matter arises from a complaint filed by Healing at Hidden River, LLC ("plaintiff", "Hidden River"), a New Jersey-based healthcare provider specializing in behavioral health and residential services for female adolescents and young women with severe eating disorders. Plaintiff operates a 22-bed residential facility in northern New Jersey, representing approximately 65% of residential eating disorder treatment beds in the state and the only such facility in the northern region.
The complaint alleges that from December 2020 through February 2025, plaintiff provided medically necessary, pre-approved residential and related healthcare services to 16 patients aged between 8 and 26, who suffered from severe eating disorders and co-occurring psychiatric conditions. These services included individual counseling, medical and nutritional assessments, recreational therapy, group therapy, on-site academics, and family involvement. The patients referenced in the complaint are identified by initials and limited patient identification numbers in accordance with privacy regulations.
At all relevant times, plaintiff was an out-of-network provider with respect to defendants, primarily the Aetna entities and several employer-based healthcare payors. The complaint asserts that Aetna and the payor defendants do not maintain an adequate network of in-network providers for eating disorder services in the region and that plaintiff was not a participant in Aetna's National Advantage Program ("NAP") nor in any MultiPlan complementary network arrangements.
Prior to admitting patients, plaintiff engaged in telephonic pre-affirmations with representatives of the defendants. According to the complaint, these representatives orally affirmed that payment for services would be at usual, customary, and reasonable ("UCR") rates or specific percentages thereof, with assurances that the claims would not be subject to repricing or to Medicare-based rate calculation. Plaintiff relied upon these affirmations when agreeing to treat the patients.
After services were rendered, the complaint alleges that claims were diverted by the defendants to Aetna's affiliate, Global Claims Services ("GCS"), for "repricing." This process purportedly reduced reimbursement rates to approximately 27% of the expected UCR rate, resulting in a cumulative outstanding payment balance to plaintiff of roughly $1.5 million. The complaint describes a self-interested "bait-and-switch" scheme in which Aetna allegedly enriched itself through administration fees and commissions on the portion of funds not paid to the provider, all while shifting the burden of underpayment onto patients who are subsequently exposed to significant medical debt.
Further, the complaint describes an industry-wide shift following prior settlements with regulators regarding manipulation of reimbursement databases. The complaint asserts that defendants have since reverted to the use of internal and affiliate-based repricing schemes inconsistent with independent UCR calculation standards.
The complaint states that jurisdiction and venue are proper in New Jersey state court, no federal claims are asserted, and no ERISA or FEHBA rights are invoked. Plaintiff claims that its exhaustion of administrative remedies was either completed where required or futile due to the nature of the defendants' appeal responses.
A complaint should only be dismissed pursuant to R. 4:6-2(e) for failure to state a claim if it fails "to articulate a legal basis entitling plaintiff to relief." Sickles v. Cabot Corp., 379 N.J.Super. 100, 106 (App. Div. 2005). On a motion to dismiss a complaint for failure to state a cause of action under R. 4:6-2(e), a court must consider whether a cause of action is "suggested" by the facts. Printing Mart-Morristown v. Sharp Elecs. Corp., 116 N.J. 739, 746 (1989) (citing Velantzas v. Colgate-Palmolive Co., 109 N.J. 189, 192(1988)).
"[T]he motion should be granted if even a generous reading of the allegations does not reveal a legal basis for recovery." Edwards v. Prudential Prop. & Cas. Co., 357 N.J.Super. 196, 202 (App. Div. 2003) (internal citation omitted). "(T]he essential facts supporting plaintiffs' cause of action must be presented in order for the claim to survive; conclusory allegations are insufficient in that regard." Scheidt v. DRS Techs., Inc., 424 N.J.Super. 188, 193 (App. Div. 2012) (internal citation omitted). Dismissals generally should be without prejudice when granted. Printing Mart, 116 N.J. at 772.
As an initial matter the court must decide which, if any, documents it will consider at this stage of the litigation. Defendants want the court to review hundreds of pages of documents with its motion, while plaintiff wants to preclude the same. The documents at issue include, among other things, alleged transcripts of phone calls referenced in the complaint (see Compl. ¶ 64) and Summary Plan Documents ("SPDs").
When considering a motion to dismiss the complaint a trial court may examine "documents specifically referenced in the complaint without converting the motion into one for summary judgment." Myska v. N.J. Mfrs. Ins. Co., 440 N.J.Super. 458, 482 (App. Div. 2015) (internal citation and quotation omitted). "In evaluating motions to dismiss, courts consider 'allegations in the complaint, exhibits attached to the complaint, matters of public record, and documents that form the basis of a claim.'" Banco Popular N. Am. v. Gandi, 184 N.J. 161, 183 (2005) (). If the court is presented with documents outside of these limits, then the court can, with proper notice, treat the motion to dismiss as a motion for summary judgment.[2]
First, defendants submitted documents which they allege are transcripts of some of the phone calls that are central to the complaint. See generally Petitt Cert. Plaintiff disputes the authenticity, completeness, and relevance of these transcripts.
Opp. Br. at 12. The 10 alleged transcripts are for 7 of the 15 patients' claims at issue in this motion.[3]
For several reasons the Defendants' arguments for submission of the transcripts fail. In Banco the New Jersey Supreme Court cited a Third Circuit case that delineates the exception to the general rule of "not considering] matters extraneous to the pleadings" on a motion to dismiss for failure to state a claim. In re Burlington Coat Fac'y Sec. Litig., 114 F.3d 1410,1426 (3d Cir. 1997); see also Lum, 361 F.3d at 222 n.3 (). There, the Third Circuit explained the underlying reasoning for the "integral document" exception, which the defendants [4] rely upon:
...
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