Quality Infusion Care, Inc. v. Health Care Service Corp.

PRADO, Circuit Judge:

This case presents a narrow legal dispute between a healthcare provider, Quality Infusion Care, Inc. (“QIC”), and an insurance company, Healthcare Service Corp., d/b/a Blue Cross and Blue Shield of Texas (“BCBS”). BCBS overpaid QIC for certain patient claims and then set off the overpayments by underpaying subsequent patient claims, without regard to whether the subsequent claim was from the same patient or under the same insurance plan. QIC argues that BCBS’s setoffs were improper because BCBS did not have a contractual or statutory right to set off over-payments against…