The U.S. Court of Appeals for the Ninth Circuit in San Francisco found that United had discretionary authority to interpret the terms of plans and that the insurer was not unreasonable in deciding the plans did not require consistency with generally accepted standards of care.

"The plans exclude coverage for treatment inconsistent with the [generally accepted standards of care]," the judges wrote. "Plaintiffs did not show that the plans mandate coverage for all treatment that is consistent with [those standards]."

In March 2019, patient advocates said coverage for mental health and addiction services could improve across all health plans following a ruling in the case from Judge Joseph Spero of the U.S. District Court of Northern California. He found UBH breached its fiduciary duty by adopting coverage guidelines that did not reflect general standards of care.

Guidelines the insurer developed for making coverage decisions were "riddled with requirements that provided narrower coverage" for patients, Spero wrote. He added that the process for developing the guidelines was "fundamentally flawed, because it is tainted by UBH's financial interests." The process then resulted in UBH making decisions about guidelines "based as much or more on its own bottom line as on the interests of the plan members, to whom it owed a fiduciary duty," the judge wrote.

However, although the plaintiffs argued that UBH had a conflict of interest, the appellate court ruled that even if the conflict could be shown it "would not change the outcome on these facts."

Attorneys for plaintiffs did not comment on the ruling.

Read more: 

• Behavioral health integration: What's stopping health care providers?
• UnitedHealth comes under fire for new diagnostic test policy
• Judge recuses himself from UnitedHealth lawsuit, citing 'barbaric' denial of treatment