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11th Circuit Denies Appeal by Out-of-Network Physician Seeking Reimbursement February 25, 2021 The Eleventh Circuit denied a consolidated appeal by a litigious physician who filed two separate complaints against United Healthcare and the patients’ employers, Coca-Cola and Delta Air Lines, that alleged Employee Retirement Income Security Act (ERISA) violations. Plaintiff W.A. Griffin’s original actions were nearly identical, stemming from the partial reimbursement she received after submitting coverage claims for two separate patients’ medical care. She argued that she should be treated as an in-network provider after invoking assignment of benefits for each patient despite being an out-of-network provider and receive reimbursement for her claims as such, the court explained. After submitting two rounds of appeals to United for each patient, Griffin filed suit. ....