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Cross-Plan Offsetting: Recent Eighth Circuit Opinion Affirms Dismissal of Cross-Plan Offsetting Case Concluding Plaintiffs Did Not...

In a recent opinion, Smith et al. v. UnitedHealth Group Inc. et al., the US Court of Appeals for the Eighth Circuit affirmed the dismissal of an Employee Retirement Income Security Act (ERISA) class action suit brought by...more

Biden Administration Issues Final Rule Expanding ERISA Fiduciary Definition, Enhancing Protections for Pension Plan Participants

On April 23, the US Department of Labor (DOL) released a final rule significantly expanding the definition of who qualifies as a fiduciary under the Employee Retirement Income Security Act (ERISA) (the Retirement Security...more

Ninth Circuit Reissues Opinion for the Second Time in Suit Challenging United Behavioral Health’s Mental Health Coverage...

Last week, the US Court of Appeals for the Ninth Circuit, in its third opinion in the case, reversed a lower court’s decision allowing patients challenging United Behavioral Health’s (UBH) internal mental health coverage...more

Court Holds NC State Health Plan Constitutes “Health Program or Activity,” Granting Summary Judgment for Transgender Plaintiffs...

On December 5, 2022, the US District Court for the Middle District of North Carolina held that the North Carolina State Health Plan (NCSHP) constitutes a “Health Program or Activity” under the Affordable Care Act (ACA). In so...more

Federal District Court Certifies Transgender Discrimination Class Action Against Third-Party Administrator Under the Affordable...

Earlier this month, the US District Court for the Western District of Washington certified a class of individuals who were denied gender-affirming care by a third-party administrator, Blue Cross Blue Shield of Illinois...more

Ninth Circuit Reverses Decision Requiring Reprocessing of 67,000 Behavioral Health Claims; Hands United Healthcare a Win 

The Ninth Circuit Court of Appeals recently reversed the Northern District of California’s landmark decision against UnitedHealth Group Inc.’s behavioral health unit, United Behavioral Health (“UBH”), under which UBH had been...more

As It Mulls Whether To Grant Cert in ERISA Case on PBM Fiduciary Liability, Supreme Court Seeks Government's Input

In December, the Supreme Court requested that U.S. Solicitor General Elizabeth Prelogar file a brief in John Doe 1 v. Express Scripts Inc., weighing in on whether the Court should hear a case about prescription drug costs. If...more

Supreme Court Unanimously Vacates Seventh Circuit ERISA Investment Fees Case

With nearly 150 similar class action lawsuits pending nationwide, the ruling is a win for the ERISA plaintiff's bar, potentially supporting their expansive view of plan fiduciaries' duty to monitor investments. As...more

Supreme Court Set To Rule This Spring on ERISA Investment Fees, Affecting Over 150 Cases Around the Country

The U.S. Supreme Court heard oral argument to decide a circuit split and determine what ERISA requires of ERISA-governed pension plan fiduciaries with respect to investment fees and recordkeeping. A decision is expected in...more

Don’t Be Insecure: DOL Guidance Addresses Cybersecurity for ERISA Plans

The Department of Labor (DOL) recently issued new guidance on best practices for maintaining cybersecurity in connection with ERISA plans (the Guidance). The Guidance, which is intended for sponsors, fiduciaries, record...more

Supreme Court Holds Arkansas Statute Regulating PBMs Not Preempted By ERISA

States seeking to regulate pharmacy benefit managers (PBMs) and prescription drug pricing received a win from the Supreme Court, which reversed an Eighth Circuit decision that had invalidated an Arkansas law governing...more

The Medicare Secondary Payer Act Prohibits Disparate Impact Discrimination, the Sixth Circuit Rules

The Sixth Circuit has issued an important decision that condemns plan provisions that provide different benefits based on a patient’s need for continued dialysis, even if the provision applies to all dialysis patients and not...more

Eighth Circuit: A State Statute that Implicitly Regulates ERISA Plans Is Preempted by ERISA

Last month, in Pharmaceutical Care Management Association v. Tufte et al. No. 18-2926 (8th Cir. August 7, 2020), the United States Court of Appeals for the Eighth Circuit invalidated legislation in North Dakota on the grounds...more

ERISA Does Not Bar Medical Providers from Enforcing Health Plans’ Payment Promises Under State Law

Medical providers treating patients covered by ERISA-governed health plans on an out-of-network basis can assert state-law claims to hold plans to their payment promises without running afoul of ERISA’s preemption provision...more

Buyer Beware: Health Plans Need to Exercise Caution in Retaining Third-Party Administrators and Medical Claim Reviewers

A federal court in Nebraska recently rejected a health plan’s fiduciary breach claims under the Employee Retirement Income Security Act of 1974 (ERISA) against third-party service providers, holding that the service providers...more

Third Circuit Upholds Anti-Assignment Provision Barring Provider’s ERISA Suit Against Insurer

The US Court of Appeals for the Third Circuit recently confirmed that “anti-assignment” provisions — provisions prohibiting insureds from assigning their rights under a health plan to third parties, including medical...more

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