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Medical Providers: How Not to State an ERISA Claim
Arent Fox via Lexology; registration required 
Oct. 19, 2015
"First, for a medical provider to state a claim under ERISA, it must have a valid assignment of benefits from the patient.... Second, to assert a claim for benefits under ERISA, that claim must be lodged against an ERISA plan.... Third, to file an ERISA claim for benefits in court, a provider with a valid assignment of benefits must first have exhausted its administrative remedies under the ERISA plan." [Pennsylvania Chiropractic Assoc. v. Independence Hospital Indemnity Plan, Inc., Nos. 14-2322, 14-3174 and 15-1274 (7th Cir. Oct. 1, 2015)]
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