Sixth Circuit: USA v. Ralph Dennis

ERISA

Health care providers have no direct standing under the Act.

Assignment of the right to payment is sufficient to guarantee derivative standing under the Act.

Where a provider and an insurer have a post-reimbursement recoupment agreement and reversal of payment is not subsequently passed back to the customer, a provider's claim that the insurer has recouped covered costs doesn't state a claim under the Act, since the insured customer is not affected by the question.

 Circuit split hinted at.

USA v. Ralph Dennis