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Text of DOL Brief in Sixth Circuit Case on Health Plan Reimbursement Provision
Office of the Solicitor, U.S. Department of Labor [DOL] 
Aug. 9, 2004
Qualchoice, Inc. v. Rowland (June 17, 2004). Excerpt: The panel's conclusion that a fiduciary's action to enforce a plan reimbursement provision is a legal action, regardless of whether the plan participant or beneficiary recovered from another entity and possesses that recovery in an identifiable fund, is inconsistent with the Supreme Court's analysis in Great-West.
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