Mealey's (January 20, 2021, 1:54 PM EST) -- ST. PAUL. Minn. — Determining whether individual health plans contain provisions precluding an insurer from offsetting overpayments against future benefit payments dooms commonality, and the named plaintiffs have not shown that they are typical of the proposed class, a federal judge in Minnesota said Jan. 14 in denying certification of the class....