Court: Look to Employer as ERISA Plan Administrator

Senior US District Judge Warren Eginton of the US District Court for the District of Connecticut dismissed the suit filed by plaintiff Brittany Tythcott after ruling it should have more properly named her father’s employer, Cooper Industries as defendant. Tythcott was a beneficiary on the Cooper health plan.

Eginton found that the health plan summary plan description (SPD) specifically named the employer’s Plan Administration Committee as the “Plan Administrator.” Although the SPD section titled “Plan Administration” referred to the TPA both as the “Benefit Administrator” and the “Plan administrator,” Eginton asserted that this ambiguity sent him to look to the TPA’s administrative service contract. Based on that contract, coupled with the plan documents, the court concluded that Cooper, rather than Aetna, was the designated plan administrator for the purposes of the Employee Retirement Income Security Act (ERISA).

 Aetna had argued that it was not the ERISA plan administrator.

Tythcott had applied for coverage for the cosmetic removal of extensive port-wine stains that had covered 25% of her body since birth. Aetna turned the request down because it was considered to be a cosmetic procedure.  

The case is Tythcott v. Aetna Life Ins., 2004 U.S. Dist. LEXIS 19628 (D. Conn. 2004). The opinion is at  http://www.ctd.uscourts.gov/Opinions/092104.WWE.Tythcott.pdf .