Chirinian v. Travelers Companies, Inc., The

CourtDistrict Court, D. Minnesota
DecidedJuly 29, 2025
Docket0:24-cv-03956
StatusUnknown

This text of Chirinian v. Travelers Companies, Inc., The (Chirinian v. Travelers Companies, Inc., The) is published on Counsel Stack Legal Research, covering District Court, D. Minnesota primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Chirinian v. Travelers Companies, Inc., The, (mnd 2025).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA

CARLIE CHIRINIAN, on behalf of Case No. 24-cv-3956 (LMP/DTS) herself and all others similarly situated,

Plaintiff,

v. ORDER GRANTING IN PART AND DENYING IN PART DEFENDANTS’ THE TRAVELERS COMPANIES, INC. MOTION TO DISMISS and THE TRAVELERS ADMINISTRATIVE COMMITTEE,

Defendants.

Philip Joseph Krzeski, Chestnut Cambronne PA, Minneapolis, MN; Oren Faircloth and Kimberly Dodson, Siri & Glimstad LLP, New York, NY; and Scott M. Haskins, Siri & Glimstad LLP, Detroit, MI, for Plaintiff.

Gina K. Janeiro, Jackson Lewis P.C., Minneapolis, MN; Lindsey H. Chopin, Rene E. Thorne, Adam R. Carlisle, and Steven Sheesley, Jackson Lewis P.C., New Orleans, LA, for Defendants.

Plaintiff Carlie Chirinian (“Chirinian”) brought this putative class action alleging that the employer-sponsored health plan of Defendants Travelers Companies, Inc., and Travelers Administrative Committee (collectively, “Travelers”) imposes a tobacco surcharge in violation of the Employee Retirement Income Security Act (“ERISA”). See generally ECF No. 1. Travelers moves to dismiss, arguing that Chirinian lacks Article III standing to bring her claims, that Chirinian’s ERISA claims are time-barred, and that Chirinian’s complaint fails to state a claim on which relief can be granted. See ECF Nos. 27, 29. The Court concludes that Chirinian largely has standing to press her claims, that her claims are not entirely time-barred, and that one of those claims survives a motion to dismiss. Accordingly, the motion is granted in part and denied in part.

BACKGROUND Legal Framework ERISA prohibits health plans governed by ERISA from requiring plan participants to “pay a premium or contribution which is greater than such premium or contribution for a similarly situated individual enrolled in the plan on the basis of any health status-related factor in relation to the individual,” such as tobacco use. 29 U.S.C. § 1182(b)(1). However,

plans may “establish[] premium discounts or rebates or modify[] otherwise applicable copayments or deductibles in return for adherence to programs of health promotion and disease prevention.” Id. § 1182(b)(2)(B). The upshot of these provisions is that employers may surcharge plan participants who do not comply with such “wellness programs,” and may offer incentives to plan participants who engage in wellness programs, without

running afoul of ERISA’s nondiscrimination rules in Section 1182. To legally surcharge plan participants, however, the plan must structure its wellness program to comply with the Public Health Service Act (“PHSA”) and federal regulations promulgated by the Department of Labor. The PHSA articulates several requirements for wellness programs, which are incorporated into ERISA. See 29 U.S.C. § 1185d(a)(1)

(providing that PHSA provisions “shall apply to group health plans” under ERISA). These requirements include that a wellness program must (1) “be reasonably designed to promote health or prevent disease,” (2) make available the “full reward” to all similarly situated individuals, (3) make available that full reward “at least once each year,” and (4) “disclose in all plan materials describing the terms of the wellness program the availability of a reasonable alternative standard.” 42 U.S.C. § 300gg-4(j)(3).

The Department of Labor incorporated these requirements into federal regulations that further specify the requirements that a wellness program like Travelers’ must meet. See 29 C.F.R. § 2590.702. Three of those regulations are at issue in this case.1 First, the wellness program “must give individuals eligible for the program the opportunity to qualify for the reward under the program at least once per year.”2 29 C.F.R. § 2590.702(f)(4)(i). The once-per-year requirement is a “bright-line standard for determining the minimum

frequency that is consistent with a reasonable design for promoting good health or preventing disease.” Incentives for Nondiscriminatory Wellness Programs in Group Health Plans, 78 Fed. Reg. 33158, 33162 (June 3, 2013) (codified at 29 C.F.R. § 2590.702). In guidance issued shortly after the promulgation of this regulation, the Department of Labor explained in the context of a tobacco cessation program:

If a participant is provided a reasonable opportunity to enroll in the tobacco cessation program at the beginning of the plan year and qualify for the reward (i.e., avoiding the tobacco premium surcharge) under the program, the plan

1 Federal regulations distinguish between four different types of wellness programs: participatory, health-contingent, activity-only, and outcome-based. See 29 C.F.R. § 2590.702(f)(1). The requirements for wellness programs depend on the type of wellness program offered. See id. § 2590.702(f)(2)–(4). Based on their citations to the Code of Federal Regulations and representations at oral argument, the parties appear to agree that Travelers’ wellness program is an outcome-based wellness program; that is, a program “that requires an individual to attain or maintain a specific health outcome . . . in order to obtain a reward,” and which may also offer “compliance with an educational program or an activity” as a means to achieve the same reward. See id. § 2590.702(f)(1)(v). The Court’s analysis therefore looks to the requirements of outcome-based wellness programs.

2 This regulatory requirement largely parrots the statutory requirement in 42 U.S.C. § 300gg-4(j)(3)(C). is not required (but is permitted) to provide another opportunity to avoid the tobacco premium surcharge until renewal or reenrollment for coverage for the next plan year.

U.S. Departments of the Treasury, Labor, and Health and Human Services, FAQs About Affordable Care Act Implementation (Part XVIII) and Mental Health Parity Implementation at 6 (Jan. 9, 2014).3 Second, the “full reward” for completing the wellness program “must be available to all similarly situated individuals.” 29 C.F.R. § 2590.702(f)(4)(iv). The Department of Labor interprets this provision to require health plans to offer “a reasonable alternative standard (or waiver of the otherwise applicable standard) for obtaining the reward” for any individual who does not meet the applicable health standard (in this case, being tobacco- free). Id. § 2590.702(f)(4)(iv)(A). Moreover, if a plan participant’s personal physician states that meeting the applicable health standard is not medically appropriate for that participant, the plan “must provide a reasonable alternative standard that accommodates

the recommendations of the individual’s personal physician with regard to medical appropriateness.” Id. § 2590.702(f)(4)(iv)(C)(4). Third, the plan “must disclose in all plan materials describing the terms of an outcome-based wellness program, and in any disclosure that an individual did not satisfy an initial outcome-based standard, the availability of a reasonable alternative standard to

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