Monday, September 21, 2015

Hamilton County Court of Appeals Rejects Public Policy Wrongful Discharge Claim Based on Alleged HIPAA and Insurance Fraud Violations

Last week, a divided Hamilton County Court of Appeals reversed a jury verdict entered in favor of a terminated physician on a public policy wrongful discharge claim on the grounds that her accusations of HIPAA and insurance fraud violations were not supported by sufficiently clear sources of public policy because neither statute imposed an affirmative obligation on the plaintiff to report her concerns or prohibited the employer from retaliating against an employee who reports violations of the statute.  McGowan v. Medpace, Inc., 2015-Ohio-3743. Unlike Cuyahoga and Franklin County Courts of Appeal, the Hamilton County Court of Appeals requires a statutory source of public policy to parallel the general whistleblower statute by requiring an employee to report concerns and to prohibit the employer from retaliation for reporting those concerns.  Also, this case rejects a prior Montgomery County Court of Appeals decision finding HIPAA to be a valid source of public policy to support a wrongful discharge claim.

According to the Court’s opinion, the plaintiff had been hired into three positions to replace a retiring physician: to be the Executive Director of two research centers and to take over the retiring physician’s private practice.  In addition, the retiring physician appointed her to replace him as the Principle Investigator on the research studies being conducted by the two research centers.   While the research centers was not affiliated with the private medical practice, they shared office space, employees and patients. Shortly after she started, the plaintiff became concerned with how the staff treated patient files (in that the research studies and medical practice operated using the same file instead of having different charts).  Staff also left the charts open on carts outside patient rooms.  She felt that this violated HIPAA.  She was also concerned that the retiring physician routinely ordered larger doses of medication than medically necessary and directed the patients to split them.   She felt that this was insurance fraud.   She also conferred with an attorney who confirmed her suspicions.  Accordingly, at the next staff meeting, she directed the staff to cease the offending practices and expressed her opinion that they violated HIPAA and insurance fraud laws.  The retiring physician learned of her accusations and removed her as the PI and from his private practice.  The defendant employer did not fire her or remove her from her ED positions, but explained that she should not have made the allegations and it could not control the retiring physician from removing her from his practice and research studies.  After she refused to apologize to the retiring physician and accused the employer of retaliation, it fired her a few weeks later.  She was awarded $800,000 in compensatory and punitive damages by a jury.  The employer appealed.

Unlike Franklin and Cuyahoga Counties, the Hamilton County Court of Appeals only recognizes narrow exceptions to the employment at will doctrine and  public policies as actionable wrongful discharge claim if the underlying statute – like the general whistleblower statute – requires the plaintiff to report concerns and prohibits the employer from retaliating against the employee for reporting those concerns:

In a claim for wrongful discharge in violation of public policy, an employee satisfies the clarity element by establishing that a clear public policy existed, and that the public policy was one that imposed an affirmative duty on an employee to report a violation, that prohibited an employer from retaliating against an employee who had reported a violation, or that protected the public’s health and safety.

With respect to the plaintiff in this case, the Court concluded that the insurance fraud statute did not impose an affirmative duty on her to report her concerns about the retiring physician’s insurance fraud or prohibit her employer from terminating her for reporting those concerns.  Accordingly, that statute could not constitute a clear source of public policy as required for a public policy wrongful discharge claim under Ohio law.

The Court reached the same conclusion with respect to the HIPAA issues even though the Montgomery County Court of Appeals had previously recognized it as providing a sufficiently clear source of public policy protecting patient’s privacy rights.  The dissent would have recognized the HIPAA public policy claim as protecting public safety.
NOTICE: This summary is designed merely to inform and alert you of recent legal developments. It does not constitute legal advice and does not apply to any particular situation because different facts could lead to different results. Information here can be changed or amended without notice. Readers should not act upon this information without legal advice. If you have any questions about anything you have read, you should consult with or retain an employment attorney.