Anti-Assignment Clause Bars Doctor’s Reimbursement Claim

Rivkin Radler’s Employee Benefit Plan Review included a summary of a case in which the U.S. Court of Appeals for the Eleventh Circuit held that an anti-assignment provision in a group health benefit plan barred direct reimbursement to an Atlanta dermatologist. The patient had executed an Assignment of Benefits in favor of the physician, a non-preferred provider under the patient’s plan, in order to have the plan pay the physician directly. A valid assignment would also have given the physician the right to sue the insurer after it allegedly underpaid the claims.