Mealey's (March 6, 2017, 2:12 PM EST) -- HOUSTON — A Texas federal judge on Feb. 15 ruled that two Cigna units may proceed on their claims under the Employee Retirement Income Security Act for fraud, negligent misrepresentation, civil conspiracy and injunctive and declaratory relief in an action alleging that ambulatory surgical centers waived payments for out-of-network patients but billed insurers as if the patients had paid (Connecticut General Life Insurance Co., et al. v. Elite Center for Minimally Invasive Surgery LLC, et al., No. 4:16-cv-00571, S.D. Texas, 2017 U.S. Dist. LEXIS 21026)....