Claims Review and Appeals Procedures

The procedures for filing claims for benefits are summarized in the respective plan overviews.

The plan administrator has the authority to control and manage the operation and administration of the plans described in this Plan Document and SPD. The person or entity responsible for specific operational or administrative duties (such as processing claims) may not be the official “plan administrator.” For some plans (such as the Short-Term Disability Plan, for example), the insurance company is the claim administrator, who has final responsibility and authority for responding to claims appeals.

For a list of the persons or entities responsible for processing claims for the plans offered by MPTN, see “Other Plan Details” within this section.

Claims Review Process

Each plan has a specific amount of time, by law, to evaluate and respond to claims for benefits covered by TERISA. The period of time the plan has to evaluate and respond to a claim begins on the date the claim is first filed.

If you have any questions regarding how to file or appeal a claim, contact the appropriate claim administrator listed in “Other Plan Details” within this section.

Initial Benefit Determination

The initial benefit determination is the first time the plan considers your claim for benefits and makes a decision on your claim.

Health Plans

Urgent Care — Who to Call

Urgent care claims should be directed to the medical utilization company by calling the number on your benefit card.

Concurrent Care — Who to Call

Concurrent care claims should be directed to the medical utilization company by calling the number on your benefit card.

Pre-Service Care — Who to Call

Pre-service care claims should be directed to the medical utilization company by calling the number on your benefit card.

Post-Service Care — Where to Write

Post-service care claims should be mailed to:

Pequot Plus Health Benefit Services
Mashantucket Pequot Tribal Nation
P.O. Box 3620
Mashantucket, Connecticut 06338-3620

For health claims, the plan recognizes four categories of claims, as explained below.

Urgent Care Claims — Claims for which, in the opinion of the treating physician, the application of non-urgent care time frames could seriously jeopardize the life or health of the patient or the ability of the patient to regain maximum function, or, in the judgment of a physician, would subject the patient to severe pain that cannot be adequately managed otherwise. This type of claim generally includes those situations commonly treated as emergencies. For urgent care health claims, the medical utilization company will notify you and your provider of their initial determination, whether adverse or not, as soon as reasonably possible, taking into account medical exigencies but not later than 72 hours after receipt of the claim, unless you or your provider fail to provide sufficient information to make a determination. In the case of such a failure, the medical utilization company will notify you and your provider as soon as possible, but not later than 24 hours after receipt of the claim by the plan, of the specific information necessary to complete the claim. Notification of the improper filing may be made orally, unless the claimant requests written notification. You and your provider will be afforded a reasonable amount of time, taking into account the circumstances, but not less than 48 hours, to provide the specified information. The medical utilization company will notify you and your provider of the determination as soon as possible, but no later than 48 hours after the earlier of the medical utilization company’s receipt of the specified information or the end of the period afforded you and your provider to provide the specified additional information.

Concurrent Care Claims— A concurrent claim is a claim for an extension of the duration or number of treatments provided through a previously-approved benefit claim. You will be notified in advance if the plan intends to terminate or reduce concurrent care claim benefits so that you will have the opportunity to appeal the decision and receive a decision on that appeal before the termination or reduction takes effect. If your concurrent care claim is an urgent claim, you must notify the medical utilization company at least 24 hours before the termination of treatment and the medical utilization company will notify you of its decision within 24 hours after receiving the claim. You will be given time to provide any additional information required to reach a decision.
Pre-Service Claims — A pre-service claim is a claim for a benefit under the plan which requires pre-certification, such as a hospital stay or when there is a question as to whether or not the service is medically necessary. For pre-service claims, the medical utilization company will notify you and your provider of the determination not later than 15 days after receipt of the claim. This 15-day period may be extended by the medical utilization company for an additional 15 days, provided the extension is necessary due to matters beyond the medical utilization company’s control and the medical utilization company notifies you within the initial period of the circumstances requiring the extension and the date by which the medical utilization company expects to render a decision. If such an extension is necessary due to you and your provider’s failure to submit the information necessary to decide the claim (request), the notice of extension will specifically describe the required information. For example, the period may be extended because you have not submitted sufficient information, in which case you will have at least 45 days to provide the information requested of you by the medical utilization company. You will be notified of the medical utilization company’s decision no later than 15 days after the end of the extended period (or after receipt of the information, if earlier).
Post-Service Claims — A post-service claim for a benefit under the plan is a claim for a benefit that has already been received. If you have filed a post-service claim for benefits, you will be notified of the claims fiduciary’s decision on your claim only if it is denied in whole or in part. The plan has up to 30 days to evaluate and respond to claims after the claims fiduciary receives the claim. This 30-day period may be extended by 15 days provided the extension is necessary due to matters beyond the control of the claims fiduciary and the claims fiduciary notifies you within the initial period of the circumstances requiring the extension and the date by which the plan expects to render a decision. In addition, the notice of extension must include the standards on which entitlement to a benefit is based, the unresolved issues that prevent a decision on the claim and the additional information needed to resolve those issues. You will be afforded at least 45 days to provide any additional information requested of you by the claims fiduciary, if the extension is due to the claim’s fiduciary’s need for additional information from you or your health care providers.

Disability Plans

For disability claims, the plan has up to 45 days to evaluate and respond to claims for benefits covered by TERISA. The 45-day period begins on the date the claim is first filed.

This period may be extended twice by 30 days each (105 days in total) if the claim administrator:

determines that an extension is necessary due to matters beyond the control of the claim administrator, and
notifies you within the initial period (and within the first 30-day extension period, if applicable) of the circumstances requiring the extension and the date by which the claim administrator expects to make a decision.

In addition, the notice of extension must include the standards on which entitlement to a benefit is based, the unresolved issues that prevent a decision on the claim and the additional information needed to resolve those issues. You will be given at least 45 days from receipt of the notice within which to provide the specified information.

Life and Accident Insurance Plans

If an application for life and accidental death and dismemberment insurance claims is denied in whole or in part, the plan will notify you or your representative in writing within 90 days of receiving the claim. This period may be extended by an additional 90 days if the claims administrator:

determines that an extension is necessary due to matters beyond the control of the claim administrator, and
notifies you within the initial period of the circumstances requiring the extension and the date by which the claim administrator expects to make a decision.

401(k) Plan

As a plan participant, you do not have to file a claim for benefits, and neither does your beneficiary. However, if you feel your benefit has been incorrectly determined and you wish to request a review of that determination, you may file a written notice with the plan administrator.

The plan administrator has up to 90 days to evaluate and respond to your claim covered under TERISA, unless special circumstances require an extension of time. This extension will not exceed an additional 90 days (180 days total) and you will receive notice of such extension before the end of the initial 90-day period. This extension notice will state the circumstances requiring the extension of time and the date by which a decision is expected. You will be notified within the initial period of the circumstances requiring the extension and the date by which the plan administrator expects to make a decision.

Health Care Flexible Spending Account

For claims for benefits from the Health Care Flexible Spending Account, the plan has up to 30 days to evaluate and respond to claims for benefits covered by TERISA. The 30-day period begins on the date the claim is first filed. This period may be extended by 15 days provided the claim administrator or its delegate:

determines that an extension is necessary due to matters beyond the control of the plan, and
notifies you within the initial period of the circumstances requiring the extension and the date by which the plan expects to render a decision.

In addition, the written notice of extension must include the standards on which entitlement to a benefit is based, the unresolved issues that prevent a decision on the claim and the additional information needed to resolve those issues. You will be given at least 45 days from receipt of the notice within which to provide the specified information.

Adverse Benefit Determination

To seek review of an adverse benefit determination for urgent care, pre-service care, and concurrent care claims, beneficiaries must contact the medical utilization company at the number on your benefits card. The medical utilization company provides a multi-level appeals process for claims denied based on medical necessity.

For post-service claims not related to medical necessity, appeals must be directed to Pequot Plus Health Benefit Services.

Adverse Benefit Determination (Applicable to All Claims)

An “adverse benefit determination” is a denial, reduction or termination of a benefit, a rescission of coverage (even if the rescission does not impact a current claim for benefits), or failure to provide or pay for (in whole or in part) a benefit. This can also include a denial of participation in the plan. For health coverage, an adverse benefit determination also means a claim denial on the grounds that the treatment is experimental or investigational or not medically necessary. This also includes concurrent care determinations.

In the event of an adverse benefit determination, the claimant will receive notice of the determination. The notice will include:

the specific reasons for the adverse determination,
the specific plan provisions on which the determination is based,
a request for any additional information needed to reconsider the claim and the reason this information is needed,
a description of the plan’s review procedures and the time limits applicable to such procedures,
a statement of your right to bring an action in the Mashantucket Pequot Tribal Court under TERISA following an adverse benefit determination on review,
for disability and health claims, if any internal rules, guidelines, protocols or similar criteria was used as a basis for the adverse determination, either the specific rule, guideline, protocols or other similar criteria or a statement that a copy of such information will be made available free of charge upon request,
for disability and health claims, for adverse determinations based on medical necessity, experimental treatment or other similar exclusions or limits, an explanation of the scientific or clinical judgment used in the decision, or a statement that an explanation will be provided free of charge upon request, and
for health claims involving urgent care, an expedited review may be initiated orally. All necessary information, including the appeal decision, will be communicated between you or your authorized representative and the plan by telephone, facsimile, or other similar method. When an appeal is expedited, the medical utilization company will respond orally with a decision within 72 hours, followed by a written notification of the decision.

Claims Fiduciary

For some plans (such as the Short-Term Disability Plan, for example), the insurance company is the claim administrator and has final responsibility and authority for responding to claims appeals.

Claims Appeal Process

If your claim is denied in whole or in part, you will receive a written notice of the adverse benefit determination. If you disagree with the initial decision, you should request a review of the claim.

For disability or health claims, you (or an authorized representative) can appeal and request a claim review within 180 days after receiving the denial notice.

For all other benefits, you (or an authorized representative) can appeal and request a claim review within 60 days after receiving the denial notice.

Be sure to state why the claim should not have been denied and submit any data, questions, or comments you think are appropriate. In connection with your right to appeal the initial determination regarding your claim, you also:

may review pertinent documents and submit issues and comments in writing;
will be given the opportunity to submit written comments, documents, records, or any other information relevant to your claim;
will, at your request and free of charge, have reasonable access to, and copies of, all documents, records, and other information relevant to your claim for benefits;
be given a review that takes into account all comments, documents, records, and other information submitted by you relating to the claim, regardless of whether such information was submitted or considered in the initial benefit determination; and
are entitled to an appeal that does not provide deference to the previous decision.

To seek review of an adverse benefit determination for urgent care, pre-service care, and concurrent care claims based on medical necessity, beneficiaries must contact the medical utilization company at the number on your benefit card. The medical utilization company provides a multi-level appeals process for claims denied based on medical necessity.

For post-service claims, appeals not based on medical necessity must be directed to Pequot Plus Health Benefit Services, as instructed above.

The request must be made in writing and should be filed with the claim administrator at the address shown for each plan under “Other Plan Details” within this section.

The claim administrator will forward the appeal request to the appropriate named fiduciary for review.

For health care plans, the review will be conducted by the plan sponsor’s appeals committee, comprised of individuals who did not make the adverse benefit determination which is the subject of the review, and are not the subordinates of those who did make that determination.

401(k) Plan Claims

You will receive written or electronic notification from the plan administrator of its decision within sixty (60) days of receipt of your appeal, unless special circumstances require an extension. If special circumstances require an extension of time to process your appeal, you will receive notice prior to the end of the original period that the time for rendering a final decision has been extended — but not beyond 120 days from the receipt of your appeal. This notice will set out the circumstances requiring an extension of time and the date by which a decision is expected.

Life and Accident Insurance and Disability Claims

For Life and AD&D insurance claims, a final decision on review shall be made not later than 60 days following receipt of the written request for review, unless special circumstances require an extension. This extension will not exceed 60 days. For Disability claims, a final decision on review shall be made not later than 45 days following receipt of the written request for review, unless special circumstances require an extension. This extension will not exceed 45 days.

If special circumstances require an extension of time to process your appeal, you will receive notice prior to the end of the original period that the time for rendering a final decision has been extended. This notice will set out the circumstances requiring an extension of time and the date by which a decision is expected.

Judicial Review

You must timely pursue all the administrative claim and appeal rights described in this section before you may seek any other legal recourse regarding claims for benefits. You may not bring any action at law or in equity to recover benefits or for an adverse benefit determination unless and until the administrative appeal rights described in this section have been exercised and the benefits requested in such appeal have been denied in whole or in part (or there is any other adverse benefit determination). If you
wish to seek judicial review of any adverse benefit determination, you must file an action in the Mashantucket Pequot Tribal Court under TERISA (Title XV, Mashantucket Pequot Tribal Law, accessible at www.mptnlaw.com) within one year after the date on which all administrative remedies are exhausted, that is, by the later of the date on which an adverse determination on review is issued or the last day on which a final decision should have been issued, or you will be forever prohibited from commencing such action.

Health Plan Claims

The claims administrator or the medical utilization company (whichever is applicable) will notify you and your provider of the plan’s determination on review within the following timeframes:

For appeals of urgent health claims, as soon as possible considering the medical situation, but no later than 72 hours for expedited appeals.
For appeals of pre-service claims, within a reasonable period of time given the medical situation, but no later than 15 days from the receipt of you or your provider’s request for appeal of a denied claim.
For appeals of post-service claims, within a reasonable period of time, but no later than 30 days after receipt of the request for appeal of a denied claim.

In certain cases, the plan may obtain a limited extension of time if notice of the extension is provided to the claimant before the end of the initial decision making period.

In all cases the benefit determination will be rendered in a consistent and nondiscriminatory manner according to the provisions of the applicable plan. The claims administrator’s decisions are conclusive and binding for first level appeals.

If you are not satisfied with the first level appeal decision of the claims administrator, you have the right to request a second level appeal. Second level appeals, for claims not related to medical necessity, are reviewed by the plan sponsor’s appeals committee. Your second level appeal must be submitted to the claim administrator within 60 days from the date you or your provider received the first level appeal decision. You or your provider will receive a decision from the claim administrator or the medical utilization company (whichever is applicable) on your second level appeal within the following time frames:

For appeals of urgent health claims, as soon as possible considering the medical situation, but no later than 72 hours for expedited appeals.
For second level appeals of pre-service claims, within a reasonable period of time given the medical situation, but no later than 15 days from the receipt of the request for review of the first level appeal decision.
For second level appeals of post-service claims, within a reasonable period of time, but no later than 30 days after receipt of the request for review of the first level appeal decision. For second level appeals, the appeals committee’s decisions are conclusive and binding.

Notices

For all TERISA claims, the claim administrator will provide written notification of the plan’s determination on review. In the case of an adverse benefit determination, such notice will indicate:

the specific reason for the adverse determination on review,
reference to the specific provisions of the plan on which the determination is based,
a statement that you are entitled to receive, upon request and free of charge, reasonable access to, and copies of, all documents, records, and other information relevant to the claim for benefits,
a description of your right to bring an action under TERISA following an adverse determination on review,
for health and disability claims, if any internal rules, guidelines, protocols or similar criteria was used as a basis for the adverse determination, either the specific rule, guideline, protocols or other similar criteria or a statement that a copy of such information will be made available free of charge upon request,
for adverse determinations based on medical necessity, experimental treatment or other similar exclusions or limits, an explanation of the scientific or clinical judgment used in the decision, or a statement that an explanation will be provided free of charge upon request, and
a description of your right to obtain additional information upon request about any voluntary appeals procedures under the plan.

In all cases the benefit determination will be rendered in a consistent and nondiscriminatory manner according to the provisions of the applicable plan. All decisions are final and binding unless determined otherwise by the Mashantucket Pequot Tribal Court.

External Review Process

The Federal external review process does not apply to a denial, reduction, termination, or a failure to provide payment for a benefit based on a determination that a participant or beneficiary fails to meet the requirements for eligibility under the terms of a group health plan.

The Federal external review process, in accordance with the current Affordable Care Act regulations, applies only to:

Any eligible adverse benefit determination (including a final internal adverse benefit determination) by a plan or issuer that involves medical judgment (including, but not limited to, those based on the plan’s or issuer’s requirements for medical necessity, appropriateness, health care setting, level of care, or effectiveness of a covered benefit; or its determination that a treatment is experimental or investigative), as determined by the external reviewer.
A rescission of coverage (whether or not the rescission has any effect on any particular benefit at that time).

Standard external review

Standard external review is an external review that is not considered expedited (as described in the “expedited external review” paragraph in this section).

Request for external review. The plan will allow a participant to file with the plan a request for an external review if the request is filed within four months after the date of receipt of a notice of an adverse benefit determination or final internal adverse benefit determination. If there is no corresponding date four months after the date of receipt of such a notice, then the request must be filed by the first day of the fifth month following the receipt of the notice. For example, if the date of receipt of the notice is October 30, because there is no February 30, the request must be filed by March 1. If the last filing date would fall on a Saturday, Sunday, or Federal or Tribal holiday, the last filing date is extended to the next day that is not a Saturday, Sunday, or Federal or Tribal holiday.

Preliminary review. Within five business days following the date of receipt of the external review request, the Plan will complete a preliminary review of the request to determine whether:
- The participant is or was covered under the Plan at the time the health care item or service was requested or, in the case of a retrospective review, was covered under the Plan at the time the health care item or service was provided.
- The adverse benefit determination or the final internal adverse benefit determination does not relate to the participant’s failure to meet the requirements for eligibility under the terms of the Plan (e.g., worker classification or similar determination).
- The participant has exhausted the Plan’s internal appeal process unless the participant is not required to exhaust the internal appeals process applicable regulations.
- The participant has provided all the information and forms required to process an external review.
- Within one business day after completion of the preliminary review, the Plan will issue a notification in writing to the participant. If the request is complete but not eligible for external review, such notification will include the reasons for its ineligibility and contact information for the Employee Benefits Security Administration (toll-free number 866-444-EBSA (3272)). If the request is not complete, such notification will describe the information or materials needed to make the request complete and the Plan will allow a participant to perfect the request for external review within the four-month filing period or within the 48 hour period following the receipt of the notification, whichever is later.

Referral to Independent Review Organization. The Plan will assign an independent review organization (IRO) that is accredited by URAC or by a similar nationally-recognized accrediting organization to conduct the external review. Moreover, the Plan will take reasonable action against potential bias and to ensure independence. Accordingly, the Plan will contract with (or direct the Third Party Administrator to contract with, on its behalf) at least three IROs for assignments under the Plan and rotate claims assignments among them (or incorporate other independent unbiased methods for selection of IROs, such as random selection). In addition, the IRO may not be eligible for any financial incentives based on the likelihood that the IRO will support the denial of benefits.

Reversal of Plan’s decision. Upon receipt of a notice of a final external review decision reversing the adverse benefit determination or final internal adverse benefit determination, the Plan will provide coverage or payment for the claim without delay, regardless of whether the plan intends to seek judicial review of the external review decision and unless or until there is a judicial decision otherwise.

Expedited external review

Request for expedited external review. The Plan will allow a participant to make a request for an expedited external review with the Plan at the time the participant receives:
- An adverse benefit determination if the adverse benefit determination involves a medical condition of the participant for which the timeframe for completion of a standard internal appeal under the final regulations would seriously jeopardize the life or health of the participant or would jeopardize the participant’s ability to regain maximum function and the participant has filed a request for an expedited internal appeal.
- A final internal adverse benefit determination, if the participant has a medical condition where the timeframe for completion of a standard external review would seriously jeopardize the life or health of the participant or would jeopardize the participant’s ability to regain maximum function, or if the final internal adverse benefit determination concerns an admission, availability of care, continued stay, or health care item or service for which the participant received emergency services, but has not been discharged from a facility.

Preliminary review. Immediately upon receipt of the request for expedited external review, the Plan will determine whether the request meets the reviewability requirements set forth above for standard external review. The Plan will immediately send a notice that meets the requirements set forth above for standard external review to the participant of its eligibility determination.

Referral to Independent Review Organization. Upon a determination that a request is eligible for external review following the preliminary review, the Plan will assign an IRO pursuant to the requirements set forth above for standard review. The Plan will provide or transmit all necessary documents and information considered in making the adverse benefit determination or final internal adverse benefit determination to the assigned IRO electronically or by telephone or facsimile or any other available expeditious method. The assigned IRO, to the extent the information or documents are available and the IRO considers them appropriate, will consider the information or documents described above under the procedures for standard review. In reaching a decision, the assigned IRO will review the claim de novo and is not bound by any decisions or conclusions reached during the Plan’s internal claims and appeals process.

Notice of final external review decision. The Plan’s (or Third Party Administrator’s) contract with the assigned IRO will require the IRO to provide notice of the final external review decision, in accordance with the requirements set forth above, as expeditiously as the participant’s medical condition or circumstances require, but in no event more than 72 hours after the IRO receives the request for an expedited external review. If the notice is not in writing, within 48 hours after the date of providing that notice, the assigned IRO will provide written confirmation of the decision to the participant and the Plan.

Recovery of Payments

Occasionally, benefits are paid more than once, are paid based upon improper billing or a misstatement in a proof of loss or enrollment information, are not paid according to the plan’s terms, conditions, limitations or exclusions, or should otherwise not have been paid by the plan. As such this plan may pay benefits that are later found to be greater than the Maximum Allowable Amount. In this case, this plan may recover the amount of the overpayment from the source to which it was paid, primary payers, or from the party on whose behalf the charge(s) were paid. As such, whenever the plan pays benefits exceeding the amount of benefits payable under the terms of the plan, the plan administrator has the right to recover any such erroneous payment directly from the person or entity who received such payment and/or from other payers and/or the participant or dependent on whose behalf such payment was made.

A participant, dependent, provider, another benefit plan, insurer, or any other person or entity who receives a payment exceeding the amount of benefits payable under the terms of the plan or on whose behalf such payment was made, shall return or refund the amount of such erroneous payment to the plan within 30 days of discovery or demand. The plan administrator shall have no obligation to secure payment for the expense for which the erroneous payment was made or to which it was applied.

The person or entity receiving an erroneous payment may not apply such payment to another expense. The plan administrator shall have the sole discretion to choose who will repay the plan for an erroneous payment and whether such payment shall be reimbursed in a lump sum. When a participant or other entity does not comply with the provisions of this section, the plan administrator shall have the authority, in its sole discretion, to deny payment of any claims for benefits by the participant and to deny or reduce future benefits payable (including payment of future benefits for other injuries or illnesses) under the plan by the amount due as reimbursement to the plan. The plan administrator may also, in its sole discretion, deny or reduce future benefits (including future benefits for other injuries or illnesses) under any other group benefits plan maintained by the Plan Sponsor. The reductions will equal the amount of the required reimbursement.

Providers and any other person or entity accepting payment from the plan, in consideration of services rendered, payments and/or rights, agrees to be bound by the terms of this plan and agree to submit claims for reimbursement in strict accordance with applicable health care practice acts, ICD or CPT standards, Medicare guidelines, HCPCS standards, or other standards approved by the plan administrator or insurer. Any payments made on claims for reimbursement not in accordance with the above provisions shall be repaid to the plan within 30 days of discovery or demand or incur prejudgment interest of 1.5% per month. If the plan must bring an action against a participant, provider or other person or entity to enforce the provisions of this section, then that participant, provider or other person or entity agrees to pay the plan’s attorneys’ fees and costs, regardless of the action’s outcome.

Further, participants and/or their dependents, beneficiaries, estate, heirs, guardian, personal representative, or assigns (participants) shall assign or be deemed to have assigned to the plan their right to recover said payments made by the plan, from any other party and/or recovery for which the participant(s) are entitled, for or in relation to facility- acquired condition(s), provider error(s), or damages arising from another party’s act or omission for which the plan has not already been refunded.

The plan reserves the right to deduct from any benefits properly payable under this plan the amount of any payment which has been made:

In error;
Pursuant to a misstatement contained in a proof of loss or a fraudulent act;
Pursuant to a misstatement made to obtain coverage under this plan within two years after the date such coverage commences;
With respect to an ineligible person;
In anticipation of obtaining a recovery if a participant fails to comply with the plan’s Third Party Recovery, Subrogation and Reimbursement provisions; or
Pursuant to a claim for which benefits are recoverable under any policy or act of law providing for coverage for occupational injury or disease to the extent that such benefits are recovered. This provision (6) shall not be deemed to require the plan to pay benefits under this plan in any such instance.

The deduction may be made against any claim for benefits under this plan by a participant or by any of his covered dependents if such payment is made with respect to the participant or any person covered or asserting coverage as a dependent of the participant.

If the plan seeks to recoup funds from a provider, due to a claim being made in error, a claim being fraudulent on the part of the provider, and/or the claim that is the result of the provider’s misstatement, said provider shall abstain from billing the plan participant for any outstanding amount(s).

Assignments

No benefit, right or interest of any participant under the plan shall be subject to anticipation, alienation, sale, transfer, assignment, pledge, encumbrance, charge, garnishment, execution or levy of any kind, either voluntary or involuntary, including any liability for, or subject to, the debts, liabilities or other obligations of such person. Any attempt to anticipate, alienate, sell, transfer, assign, pledge, encumber, charge, garnish, execute or levy upon, or otherwise dispose of any right to benefit payable hereunder or legal causes of action, shall be void. Notwithstanding the foregoing, the plan may choose to remit payments directly to providers with respect to covered benefits, if authorized by the participant, but only as a convenience to the participant. Providers are not, and shall not be construed as, “participants,” “beneficiaries” or “claimants” under this plan and have no rights to receive benefits from the plan or to pursue legal causes of action on behalf of (or in place of) participants under any circumstances.