"The fact that Cigna provided for the possibility of direct reimbursement of medical providers under the Benefit Plan did not make the providers beneficiaries ... This conclusion was supported by the assignments signed by Rojas patients because if Rojas had a right to direct payment, the assignments would not have been necessary.... The assignments only gave Rojas the right to pursue the patients' claims for payment, but did not include the right to pursue any other category of ERISA claims. Therefore, the patients did not assign a right to sue under ERISA's anti-retaliation provision ... under which Rojas sought relief." [Rojas v. Cigna Health and Life Ins. Co., No. 14-3455 (2d Cir. Jul. 15, 2015]

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