Gobeille v. Liberty Mutual: Decision

In a 6-2 decision released today, the U.S. Supreme Court has dealt a blow to state all- payer claims databases. By upholding a lower court’s decision, the Court ruled that states may no longer require self funded plans to submit claims data – that action is preempted by ERISA. In its decision in Gobeille v. Liberty Mutual, the Court was unpersuaded by the arguments presented by Vermont and the eleven amicus briefs filed in support of that state’s position. Indeed the Court concluded that “[P]reemption is necessary to prevent States from imposing novel, inconsistent and burdensome reporting requirements on plans.”

Yet health care delivery, costs and quality varies across the states as do strategies to improve how care is provided and paid for. States remain in the forefront of activity to protect public health, regulate health delivery and address health care costs and quality. States need robust data – from all payers – to meet those obligations.

Importantly, the ruling may suggest a pathway forward. In the majority opinion, the Court states: “The Secretary of Labor, not the States, is authorized to administer the reporting requirements of plans governed by ERISA. He may exempt plans from ERISA reporting requirements altogether…and, he may be authorized to require ERISA plans to report data similar to that which Vermont seeks, though that question is not presented here. Either way, the uniform rule design of ERISA makes it clear that these decisions are for federal authorities, not the separate states”

All eyes now turn to the Department of Labor (DOL). While the language of the decision does not prohibit future challenges to any DOL action, states will look to the department in hopes for a regulatory solution that will support the important work underway through state all -payer claims databases. Stay tuned, as we will keep you up to date on the implications of this decision and any response from the Department of Labor.

Gobeille v. Liberty Mutual Landing Page