"Employers providing travel-related abortion benefits frequently do so through an employer-sponsored health plan ... There is a reasonably strong argument that state laws that impose civil liability on employers for providing travel-related abortion benefits are preempted because they directly impact the plan and interfere with uniform plan administration as the employer would have to track the laws in multiple states and adjust benefits accordingly. ERISA does not, however, preempt a state's criminal laws of general applicability."

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