Judge David Hurd

MVP Health Care was claims administrator for an ERISA-covered employee health care plan provided by Haag’s self-insured employer. Diagnosed with breast cancer, Haag underwent a double mastectomy, and breast reconstruction operations performed by Koumanis—to whom Haag had assigned her right to recover plan benefits. Haag and Koumanis’ state court lawsuit asserted claims related to MVP’s alleged failure to comply with benefits claim procedures and refusal to pay the full cost of Haag’s reconstruction surgery. Action was removed to district court as governed by ERISA. In addition to concluding that Koumanis stepped into Haag’s shoes and replaced her as the only proper plaintiff, the court deemed MVP an appropriate defendant. After dismissing state law-based contract breach claims and a claim alleging violation of the Women’s Health Care and Cancer Rights Act (WHCRA), the court determined that MVP must respond to two remaining claims brought pursuant to ERISA §503 for violation of notice provisions, and ERISA §502(a)(1)(B) for recovery of full benefits under the plan. Among other things, the summary plan description provided clear notice of the coverage required by the WHCRA.