Third Circuit -- Funk v. CIGNA Group Ins

Funk v. CIGNA Group Ins

 Insurance denial was congruent with plan restrictions - employee had to be capable of earning 60% of base wages, insurance co. found him capable of returning to old job.

Where the Plan functions as a third-party administrator, there is no de facto substantial conflict of interest.

Plan language requiring repaymment of SSA proceeds sufficient to place an equitable lien against SSA income.