Though Aetna was not named as a fiduciary in the plan documents, the court ruled it could be considered a functional fiduciary because of its role in the plan.

The Employee Retirement Income Security Act of 1974—commonly referred to as ERISA— covers a wide range of benefit plans: retirement, health (or vision or dental) insurance, disability insurance, employee stock ownership, and flexible spending accounts. Under ERISA, those providing services to plans are subject to a range of requirements in carrying out their duties.

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