Cases & Deals

Blue Cross Blue Shield of Massachusetts defeats claims brought by Massachusetts Laborers’ Health & Welfare Fund

Clients Blue Cross Blue Shield of Massachusetts

In an important opinion addressing the fiduciary status of third party administrators for purposes of ERISA, Jones Day obtained a Rule 12(b)(6) dismissal of claims brought by the Massachusetts Laborers' Health & Welfare Fund against Blue Cross Blue Shield of Massachusetts. The Fund alleged that BCBSMA breached its fiduciary duties and the terms of the Massachusetts Laborers' benefit plan by failing to process claims correctly, overpaying benefits, neglecting to recoup overpayments, and refusing to provide information purportedly needed by the Fund to verify claims pricing. Jones Day convinced the U.S. District Court for the District of Massachusetts that as a third-party administrator, BCBSMA's obligations to the Fund were solely contractual in nature, not fiduciary, and that any dispute between the parties over the proper processing of claims should be governed by state contract law, not by ERISA.

Massachusetts Laborers' Health & Welfare Fund v. Blue Cross Blue Shield of Massachusetts, No. 21-10523-FDS (D. Mass. Mar. 30, 2022)