"The Eleventh Circuit held that a sub-assignee's claim for payment of a chiropractor's bills against Blue Cross and Blue Shield of Florida were within the scope of ERISA ... [T]he Court explained that the sub-assignee could have brought its claims under ERISA Section 502(a) because each count was based on an alleged wrongful denial of coverage under the plan." [Gables Ins. Recovery, Inc. v. Blue Cross and Blue Shield of Fla., Inc., No. 15-10459 (11th Cir. Dec. 1, 2015)]  MORE >>