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According to Cigna, this conduct resulted in the labs collecting more than $17 million in overpayments under healthcare plans administered by Cigna. The dispute began in 2015, when the anti-fraud unit of a managed care company, Cigna, determined that the defendant medical laboratories were engaging in fraudulent and abusive billing practices, including waiving plan members’ financial responsibility for the labs’ services-a practice referred to as "fee forgiveness" -and billing for unnecessary testing.

2021), to determine whether an ERISA plan fiduciary waited too long before bringing equitable ERISA claims against medical laboratories accused of a fraudulent billing scheme. The Second Circuit recently applied these principles in Connecticut General Life Ins. As a result, whether an equitable ERISA claim is time-barred depends on which state-law claim is most analogous and the time limitations that state law prescribes for that claim. 1132(a)(3), and therefore federal courts borrow the limitations period of the state-law cause of action to which the ERISA claim is most analogous. Federal law does not supply a statute of limitations for a claim seeking equitable relief under ERISA, 29 U.S.C.