"Employer-sponsored health plans could benefit from a ruling that ends a circuit court split that has allowed plan participants and beneficiaries in certain jurisdictions to avoid repaying plans by spending funds faster than plans could track them. Plans also would enjoy a ruling saying plan recovery language still can be enforced even if it is not in every part of the document (for example, if it is in the summary plan description only)." [Bd. of Trustees of the National Elevator Industry Health Benefit Plan v. Montanile, No. 14-11678 (11th Cir. Nov. 25, 2014; cert. pet. granted Mar. 30, 2015)]