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Failure to Follow Plan Procedures by Plan Participant Defeats Provider's Reimbursement Rights
Health Plan Law 
July 16, 2007
Excerpt: This case stands for the proposition that health care providers have no recourse against ERISA health plans that deny coverage based upon a patient's failure to follow procedures required under the plan. The provider's only recourse is to pursue claims as an assignee and, as such, will be subject to the same requirements as the plan participant.
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