Mealey's (April 26, 2023, 12:19 PM EDT) -- BOSTON — In an April 25 opinion upholding a ruling that the third-party administrator (TPA) of a self-funded health plan was not a functional fiduciary under the Employee Retirement Income Security Act, a First Circuit U.S. Court of Appeals panel did not decide a question it said “the parties and their amici vigorously dispute” — “whether the working capital amount remained a Plan asset once paid to” the TPA....