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On January 12, 2024, the Department of Labor (DOL) filed a complaint against Blue Cross and Blue Shield of Minnesota (BCBSM) alleging a series of violations pertaining to the Employee Retirement Income Security Act of 1974 (ERISA). This legal action hasn't yet drawn much attention, but it is early days and I suspect that will change as the case plays out. Certainly, the legal and employee benefits communities will be watching closely as the case raises fundamental questions about the boundaries of authority and fiduciary responsibilities in the context of third-party administrators (TPAs) of self-funded employee welfare benefit plans
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