"As a federal district court case, strict application of the ruling is generally limited to the litigants. However (especially in light of comments the [DOL] expressed in the 2019 Eighth Circuit case), it strongly appears that the prevailing view going forward deems that cross-plan offsetting violates an array of fundamental ERISA principles -- and for that reason this case holds greater than usual implications." [Lutz Surgical Partners PLLC v. Aetna, Inc., No. 15-2595 (D.N.J. Jun. 21, 2021)]