The U.S. Court of Appeals for the Third Circuit has turned back a challenge to Aetna’s requirement that parties receiving health insurance coverage for injuries caused by a third party must reimburse the company if they recover from that party.

The plaintiff, Jay Minerley, claimed his Aetna HMO policy was not an ERISA plan document that governed his benefits because his employer did not incorporate it into a document labeled as such, and because insurance policies cannot be plan documents. But the Third Circuit disagreed, finding that Minerley’s argument rested on the erroneous premise that under ERISA, an employer needs to incorporate terms of its employee benefit plan in a single document. An employee benefit plan can be collectively formed by multiple documents, which need not be formally labeled as comprising the plan, the appeals court said.