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Anti-Assignment Clauses Bar Provider’s ERISA Claims

By Carmen Castro-Pagan
An out-of-network health-care provider can’t continue with her claims under the Employee Retirement Income Security Act for unpaid benefits, fiduciary breach and failure to disclose documents against four health benefit plans, the U.S. Court of Appeals for the Eleventh Circuit ruled.
In the unpublished opinions issued Dec. 29 and Dec. 30, a three-judge panel affirmed the district court’s ruling dismissing the provider’s claims, and held that the participant’s assignment of benefits to a provider was void and unenforceable because the plans’ terms included valid anti-assignment clauses.
The cases are Griffin v. Health Sys. Mgmt., Inc., 2015 BL 428919, 11th Cir., No. 15-12138, unpublished 12/29/15 ; Griffin v. Gen. Mills, Inc., 2015 BL 428915, 11th Cir., No. 15-12157, unpublished 12/29/15 ; Griffin v. Southern Co. Servs. Inc., 2015 BL 430044, 11th Cir., No. 15-12135, unpublished 12/30/15 ; Griffin v. Focus Brands, Inc., 2015 BL 429997, 11th Cir., No. 15-12137, unpublished 12/30/15 .