"Although the scope of this decision is not clear, or whether it is an aberration, the court's opinion indicates that provisions in a plan document that provide for in-network claims to be paid directly to providers may afford such providers with 'beneficiary' status under ERISA, thus requiring the plan to follow ERISA's notice and appeals procedures when seeking to recover overpayments made to such providers. A plan sponsor should consider adding language to the plan to preclude this type of claim." [Pennsylvania Chiropractic Association v. Blue Cross Blue Shield Association, No. 09 C 5619 (N.D. Ill. Mar. 28, 2014)]  MORE >>