Question juridique clé
Whether the insured was entitled to compensation for pre-litigation attorney fees in the health-insurance proceeding.
Solution extraite
No entitlement existed because party compensation in the objection and pre-procedural administrative stage is generally unavailable; the insured also did not meet the conditions for free legal aid and no special circumstances justified an exception.
Motifs extraits
Art. 52(3) ATSG makes the objection procedure free and normally excludes party compensation. Under the case law, compensation is available only if the objecting party would have qualified for free legal aid if unsuccessful. The cantonal court's finding of lack of indigence was binding, and no special complexity or extra effort was shown.