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Valid Assignment Confers Beneficiary Status on Chiropractor
Proskauer's ERISA Practice Center Dec. 9, 2013 "The [federal district court in Illinois] ruled that one of the individual chiropractors had standing to assert claims under ERISA because the chiropractor's patients (i.e., plan participants) had assigned to him their rights to payment under their health plans and was thus an ERISA beneficiary. The court found that the chiropractor was not afforded ERISA notice and appeal rights to which a beneficiary is entitled following an adverse benefit determination, and thus granted the chiropractor summary judgment as to liability." [Pennsylvania Chiropractic Association v. Blue Cross Blue Shield Association, 2013 U.S. Dist. LEXIS 159331 (N.D. Ill. Nov. 7, 2013); 2013 U.S. Dist. LEXIS 159491 (N.D. Ill. Nov. 7, 2013)] |
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