ERISA\u27s Quantity vs. Quality Doctrine: The Eighth Circuit Limits Recovery against an HMO by Completely Preempting State Law

Health Maintenance Organizations ( HMOs ) were developed to facilitate the provision of effective care at low prices to plan members. To attain this purpose, HMOs have been required to act as both providers who administer care and gatekeepers who can deny access to care.3 The Employee Retirement Income Security Act ( ERISA ), praised as the greatest development in the life of the American Worker since Social Security, 4 regulates plans administered by IMOs. Congress has stated explicitly that ERISA was enacted to promote the interests of employees and their beneficiaries in employee benefit plans.5 In drafting ERISA, Congress sought to protect plan beneficiaries from the historical mismanagement of their pension and benefit funds6 and to avoid a patchwork scheme of state regulation that would expose plans and plan sponsors to varying substantive standards, which could potentially increase the cost of health benefits for employee