In litigation involving a health plan reimbursement claim, the Fifth Circuit ruled that a plan’s summary plan description (SPD) could serve as the plan’s “written instrument” under the Employee Retirement Income Security Act of 1974 (ERISA) (that is, the plan document) in the absence of a separate written instrument. The court concluded that the plan was entitled to reimbursement for payments made to a spouse who later settled her claim against a third party.”  Read full report at: [Thompson Reuters]