The U.S. Court of Appeals for the 9th Circuit recently ruled in the case Martin Luther King, Jr., Community Hospital v. Community Insurance Company, d/b/a Anthem Blue Cross and Blue Shield, et al. The District Court previously granted summary judgement to the hospital.
The Los Angeles, CA hospital treated employees of Budco Group who were enrolled in the company's ERISA plan, of whom Anthem was the administrator, on at lease 75 occasions between 2015 and 2017. Because the hospital was outside of Anthem's network, Anthem paid insurance benefits to the beneficiaries instead of the hospital, forcing the hospital to seek recovery from the beneficiaries, who frequently did not forward the payments to the hospital. The hospital sued, seeking to enforce their Assignment of Benefits completed by the patients and have the insurer reimburse the hospital directly. Anthem argued that an anti-assignment provision in their plan prevented patients from assigning their rights to the hospital. The Court of Appeals, in a split decision, held that the anti-assignment language cited by Anthem still allowed assignments to healthcare providers, including those that were out of network.
A full copy of the Court's opinion can be found here: https://law.justia.com/cases/federal/appellate-courts/ca9/19-55053/19-55053-2020-10-02.html