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Rethinking Pegram : Why Erisa Health Benefits Administrators Should Have A Comprehensive Legal Requirement Of Fiduciary Duty, Bradley Ray Helfand

Public Health Theses

In the 2000 case Pegram v. Herdrich, the U.S. Supreme Court decided that administrators of health benefits plans covered by the Employee Retirement Income Security Act (ERISA) of 1974 do not have a fiduciary duty towards beneficiaries when making "mixed decisions" involving treatment and eligibility components. This thesis, Rethinking Pegram: Why ERISA Health Benefits Administrators Should Have a Comprehensive Legal Requirement of Fiduciary Duty, challenges the Court's opinion on grounds of legal precedent and public health ethics. While the legal critique of Pegram is an elaboration of earlier scholarship, the public health ethics critique represents a unique contribution …