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Using 'Dummy Code' to Pass Administrative Fees Through to Health Plan May Be Fiduciary Breach
Thomson Reuters / EBIA 
July 8, 2021 "The court also observed that it would be reasonable to conclude that the claims administrator's actions -- such as referring to the subcontractor as a health care provider, and using codes that did not represent actual medical services -- violated the terms of the plan and constituted a fiduciary breach.... In addition, it appeared that the subcontractor was aware of the 'questionable nature' of the billing arrangement." [Peters v. Aetna, No. 19-2085 (4th Cir. Jun. 22, 2021)] |
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