The Seventh Circuit held that a health insurer that makes benefits determinations and pays benefit claims, rather than the health plan itself, is a proper defendant in an action for benefits under ERISA Section 502(a)(1)(B). In Larson v. United Healthcare Ins. Co., No. 12-1256, 2013 WL 3836236 (7th Cir. July 26, 2013) (unpublished), plan participants … Continue Reading
In Lifecare Management Services LLC v. Insurance Management Administrators Inc., 2013 U.S. App. LEXIS 239 (5th Cir. Jan. 4, 2013), the Fifth Circuit affirmed the district court’s ruling that a third party administrator of an ERISA welfare plan was a proper defendant in a claim for benefits under ERISA § 502(a)(1)(B) if the TPA “exercise[d] ‘actual … Continue Reading
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