On February 4, 2014, the U.S. Court of Appeals for the Second Circuit invalidated a Vermont law requiring health insurers to regularly submit health care data to a centralized database. The Second Circuit held that the state's law (as it applied to employee benefit plans) was preempted by the Employee Retirement Income Security Act of 1974 (ERISA), which governs employee benefit plans. ERISA preempts state laws that “relate to” employee benefit plans, which means that even if a state law or regulation establishes requirements for an employee benefit plan, the plan only has to follow ERISA's requirements.
In interpreting ERISA over the years, courts have recognized that regulation of health and safety are traditionally state matters and therefore, there is a presumption against preempting state health care laws and regulations. The Second Circuit's decision represents a departure from this jurisprudence, and has implications for Vermont and beyond. To learn more about ERISA, Vermont's law, and the Second Circuit's decision, we invite you to read our Fast Facts and Myth Busters on ERISA and State Reporting Laws by clicking on the links below.
Fast Facts: ERISA and State Reporting Laws
Myth Buster: States can require all health plans to report cost and quality information
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