Complaint 21-cv-4533 1

"...includes more than 50 algorithms to identify what Defendants consider unusual treatment patterns..."

"...20 psychotherapy visits within a six-month period."

"During these brief conversations, Defendants’ peer reviewers require providers to show a “clear and compelling” reason for the member to stay in treatment, and that the member is making progress in treatment."

"The care advocates frequently exceed the 20% quotas, as shown by “ALERT scorecards,” through which Defendants track compliance with imposed quotas on a daily and monthly basis. care advocates’ bonuses are based on performance, as measured by their productivity, including the number of cases they handle."