UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF ALABAMA

If you are an emergency medicine physician who participated in an RVU incentive plan with Team Health, Inc., Team Health, LLC, Paragon Contracting Services, LLC or another Team Health operating affiliate between 2014 to 2019, your rights may be affected by a class action Settlement.

A federal court authorized this Notice. It is not a solicitation from a lawyer.

A Settlement has been reached with Team Health, LLC (formerly known as Team Health, Inc.) and Paragon Contracting Services, LLC (“Defendants”), in a class action lawsuit (Forward Momentum, LLC, et al. v. Team Health, Inc., et al., No. 2:17-cv-346 (M.D. Ala.)) about whether Defendants improperly compensated emergency medicine doctors and members of the putative Class for Supervisory Relative Value Units (“RVUs”) under their independent contractor or employment agreements with Defendants from 2014 until the implementation of Variable RVU Compensation Plans. “Supervisory RVUs” include assisting RVUs and shared RVUs that are associated with a physician’s name under Defendant’s regular accounting procedures and billing guidelines, and where the physician is identified as the primary provider with another provider listed as “secondary” for billing purposes, or as the secondary medical provider for billing purposes with an APC listed as “primary.” “Variable RVU Compensation Plans” refers to the Variable RVU Compensation Plans rolled out by Defendants and Defendants’ operating affiliates beginning in 2018 and continuing throughout 2019, which used different contract language for RVU plans that laid out more explicitly when physicians did and did not get credit for supervisory RVUs. Plaintiffs acknowledge that the position of the Defendants is that this new language, on its face, does not provide RVU credit for “assisting RVUs” and does not provide full RVU credit for “shared RVUs,” as defined in the operative “Variable RVU Compensation Plan” documents.

If approved by the Court, the Settlement will establish a $15 Million Settlement Fund.

You will be included in this Settlement if you are a physician who participated in one of Defendants’ RVU incentive plans for emergency medicine physicians from 2014 until implementation of a Variable RVU plan, whether as an independent contractor or employee, if you had Supervisory RVUs associated with your name as a primary or secondary provider, but were not paid for those RVUs under your relevant RVU incentive plan. However, you are not part of the class (1) if you were enrolled in a “pool plan,” “tiered plan,” or a plan where all RVUs were determined within the “sole discretion” of Defendants; (2) if you were working at a facility where Defendants paid all RVUs, regardless of type; or (3) if your plan excluded one or more types of Supervisory RVUs. A list of relevant facilities and contractual dates excluded from this definition are available under the Case Documents tab of this website. 

The Court has not decided who is right or wrong. Instead, Plaintiffs and Defendants have agreed to a Settlement to avoid the risk and cost of further litigation.

Your rights are affected whether you act or do not act. Read the Notice carefully.

For more information, please call toll-free 1-888-256-2709.

YOUR LEGAL RIGHTS AND OPTIONS IN THIS SETTLEMENT
SUBMIT A CLAIM FORM
DEADLINE:
AUGUST 29, 2022

If you are a Class Member as defined in Frequently Asked Question 5, you must timely submit a Claim Form or you will receive no payment.

ASK TO BE EXCLUDED 
DEADLINE:
MAY 31, 2022


  

This is the only option that allows you to sue, continue to sue, or be part of another lawsuit against Defendants related to the legal claims for monetary relief this Settlement resolves.

OBJECT TO THE SETTLEMENT DEADLINE:
MAY 31, 2022 
If you do not exclude yourself from the Settlement, you may object to it by writing to the Court about why you don’t like the Settlement. If you object, you may also receive or file a claim for a payment.

GO TO A HEARING ON:
JULY 28, 2022

You may object to the Settlement and ask the Court for permission to speak at the Final Approval Hearing about your objection.
DO NOTHING If you do nothing, you will give up the right to sue, continue to sue, or be part of another lawsuit against the Defendants or their operating affiliates about the claims resolved and released by this Settlement. And if you do not timely file a Claim Form, you will receive no payment.


These rights and options—and the deadlines to exercise them—are explained in the Notice.

The Court in charge of this case still has to decide whether to approve the Settlement.