Mealey's (November 9, 2020, 1:58 PM EST) -- DALLAS — Out-of-network labs that performed testing for in-network hospitals relied on the appellate process for providers but, because they proceed under an assignment of rights, have not shown that they exhausted the administrative procedure for patients, a federal judge in Texas held Nov 4 in granting summary judgment on Employee Retirement Income Security Act claims but denying tortious interference claims against the labs (Mission Toxicology LLC, et al. v. UnitedHealthcare Insurance Co., et al., Nos. 17-1016, 18-347, W.D. Texas, 2020 U.S. Dist. LEXIS 205919, 2020 U.S. Dist. LEXIS 205927)....