Phia Group Russo & Minchoff

Plain Meaning Rules

The Tenth Circuit Court of Appeals held in Hollingshead v. Blue Cross Blue Shield of Oklahoma, 2007 WL 475832, 39 EBC (BNA) 2732 (10th Cir. 2007), that when a Plan states it will pay for only one organ transplant, the Plan may exclude charges incurred for the replacement of a previously transplanted organ that has failed.


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Adam V. Russo

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