In Albert H. Wohlers & Co. v. Bartgis (Nev. 1998) 114 Nev. 1249, the court upheld judgment in favor of an insured against a medical insurer and policy administrator based on breach of contract and bad faith.
The court held that "where a claims administrator is engaged in a joint venture with an insurer, the administrator 'may be held liable for its bad faith in handling the insured's claim, even though the organization is not technically a party to the insurance policy.'" (Bartgis, supra, 114 Nev. at p. 1262.)
The court further held that the evidence established a joint venture when the claims administrator "developed promotional material, issued policies, billed and collected premiums, paid and adjudicated claims, . . . assisted the insurer in the development of the ancillary charges limitation provision and shared in the insurer's profits." (Id. at p. 1263.)