9th Circuit In Reversal On Reimbursement: ERISA Does Not Limit ‘Self-Help’ Remedy

Mealey's (August 5, 2022, 3:29 PM EDT) -- PASADENA, Calif. — A Ninth Circuit U.S. Court of Appeals panel on July 25 reversed a California federal judge’s grant of summary judgment against a health plan and its board, ruling that the plan governed by the Employee Retirement Income Security Act “is authorized to recoup” “through its self-help provision” previously paid benefits following third-party recovery....