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Seventh Circuit: Preferred Provider Agreements Do Not Support ERISA Claim
Robinson + Cole LLPLink to more items from this source
Nov. 6, 2015
"The court expressly aligned itself with the Second Circuit, and decisions from other circuits, which distinguish between a provider's status as an assignee of a particular claim, and its status as voluntary members of a network.... [T]he court disagreed with the notion that this was a question of 'standing' to sue under ERISA ... but 'whether their claim comes within the zone of interests regulated by [ERISA].' It explained that there was value in 'keeping standing distinct from statutory coverage.' " [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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