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ERISA Subrogation Litigation in Perspective - Another Look at the Mills Decision
Health Plan Law 
[Opinion] July 27, 2007
Excerpt: Notwithstanding the outcome in any particular reported subrogation decision, a reasonable approach to negotiation of plan reimbursement provisions still remains the best approach in most cases. The alternative will be more litigation at an earlier stage involving more parties - not a good outcome for plans or their beneficiaries.
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