8.25.14 Motion to Exclude Portions of Expert Witness Testimony
Motion to Limit or Exclude Specific Opinions or Testimony of Dr. James Orr
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Transcript of Motion to Limit or Exclude Specific Opinions or Testimony of Dr. James Orr
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Respondents Motion to Limit or Exclude Dr. Orr Page 1
SOAH DOCKET NO. 529-13-0997
HHSC-OIG CASE NO.: P20111316523848911
ANTOINE DENTAL CENTER, BEFORE THE STATE OFFICE
Petitioner
v. OF
TEXAS HEALTH AND HUMAN
SERVICES COMMISSION, OFFICE
OF INSPECTOR GENERAL
Respondent ADMINISTRATIVE HEARINGS
MOTION TO LIMIT OR EXCLUDE
SPECIFIC OPINIONS OR TESTIMONY OF DR. JAMES W. ORR
COMES NOW Respondent Texas Health and Human Services Commission Office of
Inspector General (HHSC-OIG) and files this Motion to Limit or Exclude Specific Opinions or
Testimony of Dr. James W. Orr, a general dentist retained by Petitioner Antoine Dental Center as
a testifying expert in this case. Given Dr. Orrs prior testimony and conduct, Respondent
anticipates Dr. Orr will attempt to: (1) misrepresent his prior experience for a private insurance
company to claim he was the Medical Director for Medicaid for the State of Texas; (2) claim a
specialty in occlusion, a field not recognized by the Texas State Board of Dental Examiners or
the American Dental Association; and (3) offer purely speculative opinions as to what the States
Medicaid policy was for the relevant period of this lawsuit (i.e., 2008-2011) when in fact he
lacks the qualifications, knowledge, or experience to support those opinions.
Accordingly, Respondent respectfully requests the Court grant Respondents Motion to
Exclude Dr. Orrs testimony in the areas outlined above, as well as any arguments or evidence
based on such unsubstantiated opinions.
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Respondents Motion to Limit or Exclude Dr. Orr Page 2
I. APPLICABLE LEGAL STANDARD
If scientific, technical, or other specialized knowledge will assist the trier of fact to
understand the evidence or to determine a fact in issue, a witness qualified as an expert by
knowledge, skill, experience, training, or education may testify thereto in the form of an opinion
or otherwise. TEX.R.EVID. 702. The party offering the experts testimony bears the burden to
prove that the witness is qualified under [Rule] 702. Broders v. Heise, 924 S.W.2d 148, 151
(Tex. 1996). Expert testimony is admissible if (1) the expert is qualified, and (2) the testimony
is relevant and based on a reliable foundation. Cooper Tire & Rubber Co. v. Mendez, 204
S.W.3d 797, 800 (Tex. 2006), citing Helena Chem. Co. v. Wilkins, 47 S.W.3d 486, 499 (Tex.
2001);E.I. du Pont de Nemours & Co. v. Robinson, 923 S.W.2d 549, 556 (Tex. 1995).
UnderRobinson and its progeny, this Court acts as the gatekeeper of Dr. Orrs
testimony, making the initial determination about whether the expert and the proffered
testimony meet these requirements. Helena Chemical Co., 47 S.W.3d at 499; Robinson, 923
S.W.2d at 556. As the party offering Dr. Orrs testimony, Petitioner bears the burden to prove
Dr. Orr is qualified under Rule 702. See Broders, 924 S.W.2d at 151. It must demonstrate Dr.
Orr possesses special knowledge as to the very matter on which he proposes to give an
opinion. Gammill v. Jack Williams Chevrolet, 972 S.W.2d 713, 718 (Tex. 1998), quoting
Broders, 924 S.W.2d at 152-53.
The question of relevance is particularly critical in this case. As discussed below, Dr. Orr
is a general dentist who claims to be a specialist in occlusion (a specialty which does not exist,
infra), yet has been retained to offer opinions related to Petitioners orthodontic evaluation,
diagnosis, and treatment of Medicaid patients for whom Petitioner submitted prior authorization
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Respondents Motion to Limit or Exclude Dr. Orr Page 3
requests. InExxon Pipeline Co. v. Zwahr, 88 S.W.3d 623 (Tex. 2002), the Texas Supreme Court
stressed the requirement that expert testimony be relevant:
The relevance requirement, which incorporates traditional relevancy analysis
under Texas Rules of Evidence 401 and 402, is met if the expert testimony issufficiently tied to the facts of the case that it will aid the jury in resolving a
factual dispute. Robinson, 923 S.W.2d at 556 (quoting United States v.
Downing, 753 F.2d 1224, 1242 (3d Cir. 1985)). Evidence that has no relationshipto any issue in the case does not satisfy rule 702 and is thus inadmissible under
rule 702, as well as rules 401 and 402.Robinson, 923 S.W.2d at 556.
Zwahr, 88 S.W.3d at 629. Because the expert witness occupies a unique place in our
adversarial system of justice, it is critical the Court exercise its gate-keeping authority to
prevent purported experts from presenting testimony that is not based on the requisite
knowledge, training, or experience, and outside the scope of his expertise.
II. ARGUMENTS & AUTHORITIES
Petitioner has designated Dr. Orr as an expert witness who will offer opinions as to
whether Petitioner misrepresented information on prior authorization (PA) forms submitted for
reimbursement from the Texas Medicaid Program and as to the orthodontic services rendered by
Petitioner to its Medicaid patients. As shown below, Dr. Orrs veneer of credibility begins to
dissolve when his prior testimony and conduct is contrasted with the factual record in this case.
A. Dr. Orr Was Not the Medical Director for Medicaid for the State of Texas, nor
Has He Ever Been a Government Employee in a Policy-making Role
Dr. Orr is a general dentist with a private practice in Austin, Texas. Exhibit 1, Orr
Curriculum Vitae, at 1. In his resume, incorporated into Petitioners discovery responses in this
case, he describes himself as the Dental Director of The Texas Medicaid Program from 1995
to 2004. Id. at 2. In prior sworn testimony, Dr. Orr has described himself as the Medical
Director for Medicaid for the State of Texas. Exhibit 2, Deposition of James W. Orr, DDS,
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Respondents Motion to Limit or Exclude Dr. Orr Page 4
Apr. 3, 2012, at 15:20-23, 17:9-14, 18:2-4 (stating he served as Texas Medicaid Director from
1995 to the end of 2003); Exhibit 3,Hearing Transcript, Harlingen Family Dentistry v. Health
and Human Servs. Commn , SOAH Docket No. 529-12-3180, Apr. 25, 2012, at 370:25-371:2.
This misrepresentation regarding his role in the Texas Medicaid program is not limited to
litigation Dr. Orr also promotes this fiction to the general public. Exhibit 4, Have You Been
Sued Yet? New Challenges in Risk Management and Recordkeeping,Description of Lecture
Course presentation by Robert Anderton, DDS, JD, LLM and James W. Orr, DDS, June 14, 2013
(describing Dr. Orr as the former Director of the Texas Medicaid Program).
These statements are patently false. Dr. Orr was employed by the National Heritage
Insurance Corporation (NHIC), a private insurance company, as its Dental Director from 1995 to
2003. Exhibit 2, at 18:5-19:6. NHIC was a contractor retained by the Texas Health and Human
Services Commission (HHSC) to assist in implementation of the Texas Medicaid Program.
After NHICs contract with the State ended in 2003, the NHIC dissolved and Dr. Orr returned to
private practice. See id. (noting he was glad to get out). While Dr. Orr attempts to conflate his
work for NHIC a private contractor with that of a State employee or policymaker, the fact
remains he was nothing more than a claims administrator for an outside contractor which went
out of business and whose contract the State let expire nearly 10 years ago. See Exhibit 3 at
376:20-377:4, 378:19-21 (agreeing with the description of NHIC as contractors or the
administrators of the Texas Medicaid program). Furthermore, Dr. Orr was not selected to fill
the role of Dental Director for TMHP, the new contractor, when the position became open in
2004. Moreover, while at NHIC, Dr. Orr did not recall ever implementing any Medicaid policies
related to the orthodontics. Exhibit 2, at 19:14-17. Even for dental policy, Dr. Orr was one of
30 something people on the Medicaid Policy Committee. Id. at 19:18-23.
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Respondents Motion to Limit or Exclude Dr. Orr Page 5
The contrast between the false portrayal of Dr. Orr as the Director of the Texas Medicaid
Program and the truth that he was the (head) claims administrator for a private contractor hired
by the State to administer the dental portion of its Medicaid program is significant.
Respondent anticipates Petitioner will attempt to excuse or justify its conduct by offering
testimony of Dr. Orr, based on the knowledge and experience derived (or implied) by his role at
Texas Medicaid when the factual record does not support the pedestal on which Petitioner
attempts to place him. Accordingly, Respondent requests the Court exclude any statements by
Dr. Orr that he was the Director, Medical Director, Dental Director or any such title of the
Texas Medicaid program, or any state agency responsible for administration and implementing
the Medicaid program. Respondent further requests Petitioner be precluded from offering any
opinions or arguments based on such statements by Dr. Orr.
B. Dr. Orrs Claim of Specialization in Occlusion is False and Contrary to State
Regulations and Recognized Industry Standards
Dr. Orr is not an orthodontist. He is a general dentist. Yet he claims to be an occlusion
specialist, which he defines as a person who has studied and works at the way that the teeth
contact each other both sideways and up and down. Exhibit 3, at 368:22-23 (Q: What is your
specialty? A: Occlusion.), 370:3-5. In prior deposition testimony, Dr. Orr indicated he
completed a two-year residency in occlusion at the University of Texas. Exhibit 2, at 13:14-
20.1
He later backtracked; occlusion was only a major study area within a general dentistry
residency. Id. at 33:2-11. Dr. Orr also claims to be an occlusion professor, who instructs and
teaches orthodontists where and why I want the teeth. Id. at 33:7-11; Exhibit 3, at 370:6-10
(noting that he directs orthodontists, who then move the teeth).
1 He also stated he completed two years of postgraduate study in occlusion in Miami, though this specialty
coursework is not indicated on his CV. Exhibit 3, at 370:15-19; Exhibit 1, Orr Curriculum Vitae, at 1.
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Respondents Motion to Limit or Exclude Dr. Orr Page 6
Despite Dr. Orrs insistence that he possesses a specialty in occlusion, no such
specialty exists or is recognized by the Texas State Board of Dental Examiners or the American
Dental Association. See 22 Tex. Admin. Code 108.54(a),(b)(specifying the exclusive list of
nine specialties for which a dentist may advertise or use the terms specialty or specialist to
describe professional services in Texas);2 Exhibit 5, Specialty Definitions, American Dental
Assn, 1995-2013 (available at http://www.ada.org/495.aspx) (last visited May 16, 2013).
Similarly, none of the examination boards used by the State of Texas to administer specialty
examinations to Texas dentists recognize occlusion as a specialty. See 22 Tex. Admin. Code
101.2(c); Exhibit 6, Licensure by Specialty Examination, Texas State Board of Dental
Examiners; Exhibit 7, 2013 Specialty Exam Information,Western Regional Examining Board
(2013); Exhibit 8, Specialty Exam Information, North East Region Board of Dental Examiners,
Inc. (2013).
Leaving aside the open question of whether Dr. Orr has committed a violation of the
Texas Dental Practice Act by claiming and representing to the public and the court that he
has specialty training in an unrecognized field,3 Respondent urges the Court to strike Dr. Orrs
testimony to the extent he bases his opinions on any specialized knowledge or training in
occlusion as it relates to orthodontic evaluation, diagnosis, and treatment of patients. Even Dr.
Irwin Ornish, a practicing orthodontist of over 45 years who has been retained by Petitioner as an
expert in this case, rejected Dr. Orrs claimed specialty and his supposed role in instructing
orthodontists:
2 The Texas Dental Practice Act specifies that, [a]s professionals, dentists have the duty to communicate truthfully
and without deception to the public. 22 Tex. Admin. Code 108.50(b)(emphasis added).
3See 22 Tex. Admin. Code 108.54(a),(b), supra.
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Respondents Motion to Limit or Exclude Dr. Orr Page 7
Q: Have you ever used an occlusionist in your practice?
A: I'm not sure what an occlusionist is.
Q: Have you ever picked up the phone and called an occlusionist?
A: I'm not sure what an occlusionist is. It's not a recognized specialty in
dentistry.
Exhibit 9,Deposition of Irwin Ornish, DDS, May 9, 2013, at 37:3-9 (emphasis added).
Dr. Orrs lack of qualifications to provide expert opinions with regard to orthodontics is
underscored his own sworn testimony:
Q: Are you currently a practicing orthodontist?
A: No, sir.
Q: Are you a board certified orthodontist?
A: No, sir.
Q: Have you ever practiced as an orthodontist?
A: No, sir.
Q: In the last five years have you solely or independently treated apatient in the field of orthodontia from beginning stages to the end of
treatment?
A: No, sir.
Q: Are you a member of any dental associations, trade groups, specificallythat are related to the field of orthodontia?
A: No, sir.
Q: In the last year have you attended any trainings or courses related to
orthodontics?
A: No, sir.
Q: Do you have any postgraduate residency in orthodontia?
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Respondents Motion to Limit or Exclude Dr. Orr Page 8
A: No, sir.
Exhibit 3, at 368:1:22 (emphasis added);4
see also Exhibit 1, Orr Curriculum Vitae (indicating
lack of publications, peer-reviewed or otherwise, relating to orthodontics). The factual record is
clear: there are four designated experts in this case; three are orthodontists, and Dr. Orr is not
one of them. Accordingly, any opinions Dr. Orr seeks to proffer regarding orthodontic
evaluation, diagnosis, or treatment, based on his claimed specialty in occlusion, should be
excluded.
C. Dr. Orrs Opinions as to Texas Medicaid Policy in 2008-2011 are Purely Speculative
Despite Dr. Orrs attempt to portray himself as the voice of the Texas Medicaid Program
as it related to dental and orthodontic claims, the evidence does not support, and in fact, refutes,
such a characterization. Moreover, there is no evidence Dr. Orr has any personal knowledge or
relevant insight as to what Medicaid policy related to dental or orthodontic claims would have
been during the 2008 to 2011 period at issue in this lawsuit. Even while at NHIC, Dr. Orr had no
role in implementing Medicaid policy with regard to orthodontics and was one of 30 something
people on the Medicaid Policy Committee for dental policy. Id. at 19:14-23. In addition, Dr.
Orr himself concedes he has had no meetings with anyone at TMHP or the Medicaid program
regarding dental policies since his departure from NHIC in 2003. Exhibit 2, at 19:14-20:15
(noting his only knowledge in recent years regarding the Texas Medicaid policy is through
reading the Texas Medicaid Provider Manual). Similarly, in prior deposition testimony Dr. Orr
conceded he has no knowledge of the Medicaid prior authorization process after he left his
position at NHIC:
4 Petitioner may argue Dr. Orrs qualifications in orthodontia arise from his experience evaluating claims
submitted for Medicaid reimbursement while Dr. Orr was employed by NHIC. However, his NHIC position was
not a clinical one; Dr. Orr never actually saw or evaluated any of the patients only their score sheets. Exhibit 3, at372:9-15.
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Respondents Motion to Limit or Exclude Dr. Orr Page 9
Q: And how is the prior authorization process differ today than when you
were Dental Director?
A: Counsel, I do not know. I'm not familiar with the process as it's been
since I left on a detailed basis, to answer your question.
Exhibit 2, at 21:6-10 (emphasis added).
To summarize, Dr. Orrs only personal knowledge and experience with the Texas
Medicaid program is as a claims administrator through his employment with NHIC, a private
insurance company contracted by the State to administer the Medicaid program until 2003. He
has no continuing knowledge regarding Medicaid policy since the time NHICs contract expired
in 2003, nor has he had any policymaking role with the Texas Medicaid program in the ensuing
10 years, including the years at issue in this lawsuit. As such, any opinions he would render as to
whether Petitioner committed any policy violations between 2008 and 2011 under the Texas
Medicaid Program would be purely speculative and not based on any relevant, specialized
training, knowledge, or experience.
III. CONCLUSION & PRAYER
Respondent respectfully requests the Court grant Motion to Limit or Exclude Dr. Orrs
testimony in each of the areas outlined above, including: (1) any statement implying that he was
a Director (or any such title) of the Texas Medicaid Program or made policy regarding Texas
Medicaid, when in fact he was a claims administrator for a private insurance company hired as
an outside contractor; (2) any statement or opinion based on his claimed specialty in
occlusion, when there is no such specialty in dentistry or orthodontics; or (3) any opinions as
to what Texas Medicaid policy was in 2008-2011 during the years Petitioner allegedly engaged
in conduct that was unlawful, fraudulent, or otherwise in violation of the Texas Medicaid
program. Respondent further requests any additional relief to which it is justly entitled.
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Respondents Motion to Limit or Exclude Dr. Orr Page 10
Respectfully submitted,
Dan Hargrove________________________
Dan Hargrove
State Bar No. 00790822WATERS & KRAUS, LLP
3219 McKinney Avenue
Dallas, Texas 75204(214) 357-6244 Telephone
(214) 357-7252 Facsimile
~and~
Jim Moriarty_______________________
James Moriarty
State Bar No. 14459000MORIARTY LEYENDECKER, PC
4203 Montrose Blvd, Suite 150
Houston, TX 77006(713) 528-0700 Telephone
CERTIFICATION OF SERVICE
The undersigned counsel for Respondent, hereby certifies that a true and correct copy of
the foregoing document was served on counsel for Petitioner via facsimile and certified mail,
return receipt requested on this the 20th day of May, 2013.
Dan Hargrove_______________________
DAN HARGROVE
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