Mealey's (August 10, 2015, 10:48 AM EDT) -- NEW ORLEANS — A health plan participant who was denied benefits for failure to obtain prior authorization for hospital expenses was entitled to summary judgment under the Employee Retirement Income Security Act because the administrative record did not show that the participant received services at a “hospital,” the Fifth Circuit ruled July 29 in an unpublished opinion (Rebecca Hamsher v. North Cypress Medical Center Operating Company, Limited, No. 14-20576, 5th Cir.; 2015 U.S. App. LEXIS 13409)....