On the heels of the Supreme Court’s decision in Heimeshoff v. Hartford Life & Acc. Ins. Co, a federal district court in New York has held in Halpern v. Blue Cross/Blue Shield of Western New York, 12-CV-407S (W.D.N.Y., Sept. 4, 2014) that a group health benefit plan’s shorter one-year limitations period is unenforceable because section 3221(a) of New York Insurance Law allowed for a two-year limitations period. Despite the fact that the New York’s Superintendent of Insurance approved the plan and had discretion to approve policies with provisions deviating from section 3221’s requirements, the court determined that a policy provision approved by the Superintendent could not run counter to the existing law.
Home > Federal Law Articles > Employee Benefits > General (Benefits) > Federal District Court Holds That Plan’s One-Year Limitations Period Is Unenforceable Under State Law