Self-Funded Health Benefit Plans

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Abstract
ON JUNE 3, 1985, the Supreme Court decided that states may require group health insurance plans to cover certain specified types of care for employees.1At issue in the case was whether the Metropolitan Life Insurance Company could be required by the Commonwealth of Massachusetts to provide 60 days of inpatient treatment in a mental hospital and certain minimum outpatient benefits in its health insurance plans. On the surface, this judgment bolsters the ability of states to enforce mandated benefit laws. Beneath the surface, however, and of greater overall significance, is the victory this case represents for employers who fund their own employee health benefits, who are not covered by this decision. In contrast, the commercial insurance industry and Blue Cross/Blue Shield, whoarecovered by this decision, are now bound to offer what the various states require as minimum benefits for their residents. The Court's ruling calls attention to

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