Supreme Court rules self-insured plan data exempt from all-payer databases
In a case that has ramifications for states’ efforts to create all-claims databases, the U.S. Supreme Court 6-2 today that the federal Employee Retirement Income Security Act of 1974 preempts a Vermont law requiring that claims from a self-funded employer plan be reported to the state’s database. In the case, Gobeille v. Liberty Mutual Insurance, Vermont argued that the 2nd Circuit Court of Appeals’ decision was inconsistent with Supreme Court precedents on ERISA preemption and would impair significantly state regulation of health care, especially in states with claims reporting programs similar to Vermont’s; Liberty Mutual contended that the decision is consistent with prior decisions preempting state laws that have an impermissible “connection with” ERISA-covered plans. In writing for the majority, Justice Anthony Kennedy sided with Liberty Mutual saying “The state statute imposes duties that are inconsistent with the central design of ERISA, which is to provide a single uniform national scheme for the administration of ERISA plans without interference from laws of the several States even when those laws, to a large extent, impose parallel requirements.” The AHA and Association of American Medical Colleges last fall submitted a friend-of-the-court brief supporting Vermont’s position.