Chaz Posted September 12, 2011 Posted September 12, 2011 Does anyone have any thoughts on what the effect of PPACA's external review procedures have on the ERISA concept of claims fiduciary? I'm not sure anything changes but if a participant can have a review from an independent third party that overrides the decision of the plan administrator or third party administrator, can a case be made that the respective administrator is not a fiduciary with respect to claims determinations?
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