Mealey's (March 24, 2021, 8:26 AM EDT) -- PORTLAND, Ore. — An insured’s claim that his health care provider violated Montana state law after his bill for medical treatment was $17.27 more than his annual out-of-pocket maximum is preempted by the Employee Retirement Income Security Act, a Ninth Circuit U.S. Court of Appeals panel ruled March 11, dismissing a statement by the health plan’s attorney calling the plan a non-ERISA one as “irrelevant.”...