Another Federal Court Agrees: In-Network Medical Providers Are “Beneficiaries” Under ERISA

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A federal Court in Wisconsin recently joined the chorus of courts that have applied the definition of “beneficiary” under ERISA to conclude that in-network medical providers meet the definition because they are paid directly under the terms of the patients’ health plans.
 
In the recent Wisconsin case, the parties each argued the opposite of what is typically argued by them: the insurer, Aetna, argued not only that ERISA applied, but that it pre-empts all state law (wipes it out as though it does not exist). In addition, Aetna argued that the plaintiff in the case, a hospital, was a “beneficiary” under ERISA because it got paid directly, under the patient’s plan.
 
This legal approach has been advanced by Quadrino Law Group in cases throughout the country, and courts are now realizing that the patients’ assignment document is not even relevant if the provider is in network and paid directly under the plan. In fact, the Wisconsin court dismissed the hospital’s comments about its assignment document from the patient and held that it was not relevant because the hospital is a “beneficiary” due to a plan designation to receive benefits — as the language of the statute requires.
 
The other remarkable aspect of the Wisconsin case is that Aetna also admitted that all state law legal claims are pre-empted, and the court agreed.