## Facts

- Vermont required specified health-sector entities to report eligibility, claims, and services data to a state agency for an all-payer claims database intended to support statewide cost and quality analysis.
- Liberty Mutual sponsored a self-insured employee health benefit plan governed by ERISA and covering employees nationwide.
- Liberty Mutual used Blue Cross Blue Shield of Massachusetts as a third-party administrator for plan administration.
- Vermont subpoenaed Blue Cross to produce plan-related eligibility, medical claims, and pharmacy claims files for Vermont members.
- Liberty Mutual directed Blue Cross not to comply, asserting ERISA preemption and concern that compliance could conflict with ERISA-based fiduciary obligations.
- Liberty Mutual sought declaratory and injunctive relief to prevent enforcement of the state reporting regime against its plan.

## Issues

1. Whether ERISA’s express preemption clause preempts a state statute and regulations requiring reporting of health care claims and related data to a state all-payer claims database when applied to a self-insured ERISA plan and its third-party administrator.
2. Whether a state reporting mandate has an impermissible “connection with” ERISA plans by regulating core aspects of ERISA plan administration and disrupting nationally uniform administration.

## Decision

- The Supreme Court affirmed the Second Circuit, holding 6–2 that Vermont’s reporting, disclosure, and recordkeeping requirements are preempted by ERISA as applied to ERISA plans.
- The Court reasoned that ERISA’s reporting and disclosure scheme is central to plan administration and is designed to be nationally uniform.
- The Court concluded that allowing state-by-state reporting mandates would create duplicative, inconsistent obligations and impose additional administrative burdens on ERISA plan administration.
- The Court emphasized that decisions about additional reporting obligations for ERISA plans are assigned to the Secretary of Labor under ERISA’s structure.
- Concurring opinions agreed with preemption under existing doctrine (Thomas) and highlighted that federal rulemaking could address data-sharing with state databases while preserving national uniformity (Breyer).
- The dissent would have upheld Vermont’s law as a traditional health regulation with only incidental effects on ERISA plan administration and no direct regulation of plan benefits or participant relationships.

## Legal Principles

- ERISA preempts state laws that “relate to” ERISA plans, including laws with an impermissible “connection with” ERISA plans.
- A state law has an impermissible connection with ERISA plans when it governs a central matter of plan administration or interferes with nationally uniform plan administration.
- ERISA’s reporting, disclosure, and recordkeeping requirements are core components of ERISA’s uniform administrative scheme; states may not impose additional, independent reporting regimes on ERISA plans in that domain.
- The risk of multiple state reporting mandates—duplicative filings, inconsistent standards, and conflicting deadlines—supports preemption to protect uniform administration and reduce administrative burdens.
- Authority to require, modify, or exempt ERISA plan reporting obligations is primarily vested in federal administration through the Secretary of Labor, rather than in state regulators.

## Conclusion

The Court held that ERISA preempts Vermont’s all-payer claims database reporting mandates insofar as they require a self-insured ERISA plan (or its third-party administrator) to submit claims and eligibility data, because such requirements intrude on ERISA’s federally controlled, nationally uniform system for plan reporting and administration.


Gobeille v. Liberty Mut. Ins. Co., 577 U.S. 312 (2016)