Emergency Physicians Integrated Care v. Salt Lake County

167 P.3d 1080 (2007)

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Nature of the Case

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Facts

Prior to 2001, D paid P physicians for the care they provided to convicted and pretrial inmates in accordance with its own administrative guidelines and the applicable provisions of the Utah Code. The legislature amended the provision of the Code that lists the charges for which a county is statutorily responsible. Counties are required to pay medical facilities for uncovered medical services provided to convicted and pretrial inmates at noncapitated Medicaid rates, absent a separately negotiated fee schedule between the county and the facility. D began reimbursing P physicians for inmate care at the noncapitated state Medicaid rates. P contends that section 17-50-319, which covers charges by 'medical facilities,' is inapplicable to charges provided by its physicians. P claims that because the noncapitated state Medicaid rate is substantially less than the 'usual and customary charges' for its physicians' services, it is entitled to additional compensation. P also contends that D failed to make any payments for care provided to some of the inmates. P moved for partial summary judgment under the equitable theory of quantum meruit. D claims the payments are limited to the noncapitated state Medicaid rates. Reasoning that the inmates, rather than D, were the primary beneficiaries of the services provided, the district court held that P's quantum meruit claim failed as a matter of law because P conferred only an incidental benefit on the County. The court also concluded that D had no statutory obligation to pay physicians for the medical care they provided to inmates. The implication of the district court's ruling is that D has no legal obligation to reimburse P’s physicians at all for medical services provided to county inmates. P appealed.