"[At issue was the] remedy an out-of-network medical care provider has when an insurer ... [agrees] to pay reasonable rates for services that are not covered in the ERISA benefit plan ... only to later refuse to pay the provider's invoices.... The Third Circuit determined that the Surgery Center's causes of action for breach of contract and equitable estoppel did not 'reference' an ERISA plan because the side agreement does not require interpretation or analysis of the plan terms.... The Surgery Center's claims for breach of contract and equitable estoppel were also found not to have a 'connection' to any ERISA plan." [The Plastic Surgery Center., P.A. v. Aetna Life Ins. Co., No. 18-3381 (3d Cir. Jul. 17, 2020)]  MORE >>