July-August 2025

Federal Appeals Court Reverses Dismissal of ERISA Healthcare Fee Suit Against Third-Party Administrator

Employee Benefit Plan Review
Lindsey R. Camp | Todd D. Wozniak | Monica I. Perkowski

Litigation attorneys Lindsey Camp, Todd Wozniak and Monica Perkowski co-authored an article featured in the Employee Benefit Plan Review analyzing the U.S. Court of Appeals for the Sixth Circuit's recent decision in Tiara Yachts Inc. v. Blue Cross Blue Shield of Michigan. The court reversed a lower court dismissal and held that a third-party administrator (TPA) could be deemed an Employee Retirement Income Security Act of 1974 (ERISA) fiduciary if it exercises sufficient control or discretion over plan assets, even when acting under a contract. The authors explain that this ruling underscores the broad scope of ERISA fiduciary duties for TPAs and highlights the importance of regular plan audits and documentation. Their article also offers key takeaways for sponsors and fiduciaries navigating complex litigation risks.

The attorneys also published a Holland & Knight alert on this topic.

READ: Federal Appeals Court Reverses Dismissal of ERISA Healthcare Fee Suit Against Third-Party Administrator

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