The Third Circuit recently held that anti-assignment clauses in ERISA-governed healthcare plans are enforceable as long as they are unambiguous. The Court concluded that the anti-assignment clause clearly stated that participants could not assign their rights under the plan; and the plan's statement that payments made directly to a provider did not transfer to that provider any legal or equitable rights under the plan did not render the clause any less clear or imply that payment and an assignment of rights should be treated as synonymous. In so ruling, the Court rejected the provider's argument that the anti-assignment clause was invalid because it did not explicitly state that an assignment is void or that the purported assignee acquires no rights in the event of a non-conforming assignment. Accordingly, the Court concluded that the provider lacked statutory standing to assert a claim for benefits under ERISA. The case is University Spine Center v. Aetna, Inc., No. 18-2842, 2019 WL 2149590 (3d Cir. May 16, 2019).
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