The Court determined that RMI, as Independent Fiduciary has authority to commence its proposed liquidation plan without the need for Court Approval.  The Plan RMI will follow is attached for your convenience. Click here to review the Plan of Liquidation and the related exhibits.


Additionally, RMI has been notified by HMA that approximately 150 Plans which terminated on June 30, 2021 and are now in the final month of wind-down will be required to make additional contributions on or before December 31, 2021 in order to be eligible to apply for stop loss coverage. Of course, there is no guarantee the applicable plan will ultimately be eligible for stop loss coverage but failure to contribute the needed amounts by December 31, 2021 will make the Plan Sponsor responsible for the full amount because stop loss coverage will not be available. HMA is gathering the records and RMI anticipates making phone calls to the effected Plan Sponsors and Brokers of Record if applicable starting December 15, 2021.


RMI has received a number of questions regarding Broker Commissions in the Medova litigation.  Below is a brief Q&A which RMI hopes will be helpful to you regarding commissions and the requirement for a Broker of Record Document from the Employer:


When should you expect your first commission statement from HMA?


The answer to this question will largely depend upon the analysis that is currently being performed on all active and run-out ERISA Medova plans by HMA.  Due to a delay from CHS and Medova in getting all necessary data to HMA, the full conversion process has been delayed by almost a month.  This analysis will determine the funding shortfalls in plans we may have. Should there be any funding shortfalls, obviously that will delay the payment of commissions. 

A part of this analytical exercise is also identification of those claims that may be covered by stop loss policies (both specific and aggregate).  RMI’s goal is to maximize the benefits afforded by the stop loss policies to aid the employer in meeting its funding obligations.  Once medical claims are funded, commissions may resume or be directly funded (caught up) by the employer.  RMI would not expect a commission statement on an underfunded plan to issue prior to October 1, 2021.  Should a plan not have funding issues, those commissions and statements may resume earlier.

Will the IF still have control over the commission payments and amounts?


The short answer is Yes.


Will the commissions that have not been paid over the last few months for cases that RMI has identified as ‘underfunded’ health plans ultimately be back paid? If so, when?


The obligation to pay commissions is a part of the employer’s responsibility.  Should a plan no longer be ‘underfunded’ (if the plan can meet its medical claims expenses), those funds for commissions will be reviewed and paid.  If an employer does not fund the plan expense of commissions, the employer and broker will be notified at that time after the plan’s medical claim expenses are resolved.

Why have non-ERISA accounts been withheld when the IF has no control or jurisdiction over them?


In limited situations, the IF has jurisdiction over non-ERISA funds.  One reason is that in certain circumstances, non-ERISA plans are reliant upon payments from the applicable accommodation funds. Medova has used accommodation funds for more than just medical expenses. Secondly, under the terms of the Consent Order, RMI has had control of all accommodation funds. {These funds have now been returned to the Stop Loss Carriers.}  Medova failed to submit any supporting documentation or evidence of any procedure used to establish amounts to be deducted for plans (ERISA or non-ERISA) from the accommodation funds that were congruent with the aggregate stop loss policies that control this feature. Additionally, Medova represented certain plans to be ERISA when they were not and represented certain plans to be non-ERISA when they were not.  This created a circumstance that may have delayed those commission payments.

What is the procedure for a broker to obtain information from RMI or HMA regarding an employer sponsored plan?


Because of some recent issues regarding alleged misrepresentation by parties of who they represent, RMI and its appointed third-party administrator, HMA, will no longer communicate directly with ANY broker regarding ANY MATTER until the employer sponsor has executed and submitted a Broker of Record form (link below) to Robert Moore and RMI has confirmed its authenticity with the employer. This form MUST be on the Sponsoring Employer’s letterhead and notarized. Any Broker of Record form submitted that is not on the Sponsoring Employer’s letterhead and that has not been notarized will not be accepted as valid.  RMI has the authority as the Court-Appointed Independent Fiduciary to communicate directly with any employer sponsor of an ERISA plan, any employer member, and any stop loss carrier at any time, regardless of the involvement of a broker. 


The Broker of Record template form is linked HERE



It has come to the attention of Receivership Management Inc.(RMI) the court appointed interim Independent Fiduciary that many hospitals and medical providers are seeking to comply with Judge Crouse’s Order but may not have knowledge as to which of their patients may be covered by the Court’s Injunction.  To that end, we have posted a searchable listing of Group Names, Group ID Numbers and Member ID Numbers to assist medical providers in their efforts to comply with the Court’s Injunction.  You may access this listing by clicking here: Searchable Listing


Information concerning the Injunction, current actions regarding the Lifestyle Health Plans/Bridgewater Plans is discussed below. A link to the Court’s Injunction Order is also below.



On Friday, May 14, 2021, Receivership Management Inc. (RMI), the Interim Independent Fiduciary of the Medova Lifestyle Health Plans, and Medova Healthcare Financial, LLC (Medova), agreed that Medova would be replaced with a new Third Party Administrator (TPA) to provide TPA services to those Lifestyle Health Plans covered by the federal Employee Retirement Income Security Act of 1974, as amended (ERISA). The transition to a new TPA for ERISA Medova Plans will be completed no later than July 1, 2021. RMI notified the Court on May 21, 2021.




RMI and Medova agreed that the ERISA Lifestyle Health Plans serviced by Medova will begin the transfer process immediately, with the transfers to be completed no later than July 1, 2021. Medova will continue to service the Lifestyle Health Plans until that transfer has occurred. Medova will also continue to serve as a TPA to Lifestyle Health Plans that are sponsored by employers who are governmental entities or religious organizations.





The new TPA will be Hawaii Mainland Administrators of Tempe, Arizona (HMA). HMA is a large TPA with experience handling numerous health plans. The new TPA has banking privileges with Arizona Bank and Trust, which is where RMI will move the ERISA Lifestyle Health Plan accounts. RMI appreciates Medova’s agreement to the transition to HMA by July 1, 2021. During the transition, there will be continuing work and contact with Medova.


RMI continues to ask for the patience and understanding  of the many thousands of ERISA health plans’ brokers, members, patients and providers of the over 2,500 Medova Health Plans. RMI believes this change will improve response time but transitions are always challenging. RMI has been working diligently – nights and weekends included – to help the ERISA Lifestyle Health Plan members, patients, brokers and providers, and we will continue to do so.  We understand the frustration you are experiencing and we will do our best to assist whenever possible.   We are responding to calls, emails, faxes and letters as soon as we can but the volume is quite high so, please be patient with us.




It is important to understand RMI has not been appointed to address non-ERISA health plans handled by Medova. Further, Medova will continue to serve as a TPA to Lifestyle Health Plans that are sponsored by employers who are governmental entities or religious organizations.  Medova is also the continuing contact for all inquiries regarding non-ERISA Medova health plans.




For all Medova ERISA Health Plans until you are notified that your Lifestyle Health Plan has completed its transition, you should continue to contact Medova to:


1.      submit new claims;

2.      obtain required authorizations and pre-authorizations;

3.      obtain claims status;

4.      file an appeal and seek information regarding  appeals for pending claims;

5.      obtain copies of explanation of benefits (EOBs) and ask questions regarding EOBs; and

6.      pay premiums as instructed.


If you are unable to obtain the necessary information, please call RMI at 615-370-0051.  Non-ERISA Medova Plans will continue contacting Medova regarding all of the above matters and Medova will continue as their TPA after the transition.




ERISA Medova Health Plan members, who have unpaid claims over 90 days in arrears, should provide the following information to by encrypted email with “Medova Unpaid Claims” in the subject line to or by fax to 615-373-4336:

1.               the Member’s full name;

2.               the Name of the Member’s Employer;

3.               Provide a copy of the Health Plan Card or provide your Member ID Number;

4.               the Patient’s full name and date of birth;

5.               the Claim Number, if known;

6.               the Provider’s name and address;

7.               the Date of Service(s);

8.               the Amount Billed;

9.               Copies of any Explanation of Benefits (EOBs) or bills you have received;

10.            Have you been subjected to collection action regarding Medova’s portion of a bill?  _______ If yes,  please provide copies of the collection notices; and

11.            Have you filed an appeal? _____ If yes, please provide copies of the appeal documents.


If you do not have all the documents, you should send what you have available.  The more information you provide the easier it is to identify your claims and to seek information.



RMI has issued Requests for Information (RFIs) to Medova regarding a number of unpaid ERISA Medova claims.  Medova is still obligated to respond to the requests.  Please be patient as we continue to try and obtain responses from Medova. 

During the transition, RMI plans to only issue additional Requests for Information for persons we were already working with prior to the TPA change.  We will address new issues with the new TPA after July 1.  RMI will wait a few weeks to allow the new TPA some transition time. Again, please be patient with us.



     For ERISA Health Plan Members and Patients who are receiving collection notices and action regarding amounts owed by your ERISA Lifestyle Health Plan, U.S. District Court Judge Toby Crouse issued an Order under the All Writs Act enjoining collections and lawsuits against members and patients covered by the ERISA Lifestyle Health Plans. Click the link here to view the Order.  RMI is also offering the following suggestions to Members and Patients with unpaid claims owed by the Plan to do the following:

1.  Continue to gather and retain the information described above for claims unpaid by Medova for more than 90 days.  Keep copies for yourself and provide to RMI as described above.


2.  The Member should notify the Collection Entities in writing that you dispute the debt because it is owed by the ERISA Lifestyle Health Plan to the Provider (if such is the case). You can also notify the Collection Entities of the Motion filed by the Department of Labor and provide them with a copy.  The Member should copy the letter to the Provider and RMI by encrypted email with “Medova Collections” in the subject line to or by fax to (615) 373-4336.


3.  Review available consumer educational materials regarding debt collection and credit reporting.  For example, the Federal Trade Commission has excellent consumer information regarding how to dispute errors on credit reports and debt collection at


4.  If legal action is taken against a Member or Patient, the Member needs to respond within the legally required time frame and may need an attorney.  RMI would also ask that you provide copies of any legal action taken asap to RMI by encrypted email with “Medova Lawsuit” in the subject line to or by fax to (615) 373-4336.



          Please understand RMI cannot pay claims where the particular ERISA Lifestyle Health Plan is currently underfunded. ERISA Lifestyle Health Plans rely on contributions by the Sponsoring Employer and a combination of Stop Loss policies. Many of these Stop Loss policies will not make their payments until the end of the Policy term. Gaps that occur between the amount of funds paid by the Employer and the Attachment Point of the Stop Loss Policy are to be funded by the Employer.


Shortfalls between the medical expense amounts funded by the Employer and the Stop Loss Attachment Point are to be funded by the Employer as outlined in the Plan Document adopted by the Employer. Amounts above the Stop Loss Attachment Point MAY be required to be funded by the Employer in accordance with the Stop Loss Policy unique to the Employer’s Plan.  Some or all of the amounts above the Stop Loss Attachment point paid by the Employer  may be refunded when Stop Loss payments are received.




RMI, as Interim Independent Fiduciary, has determined that, if an ERISA Lifestyle Health Plan is unable to pay its medical claims, RMI will not approve payments for insurance brokerage commissions.




          Some employers and brokers have contacted RMI regarding termination of their plans. RMI cannot advise employers or their insurance brokers regarding the employers’ business decisions. RMI would advise employers and brokers to carefully review their Plan Document and Stop Loss Policies to determine how they would be impacted by an early termination. Employers may wish to consult an attorney regarding such an important contractual decision.


          Please note:  ERISA Lifestyle Health Plans cannot be renewed.  At the end of the plan year, the Employer has the authority to decide whether to establish a new health plan or not to establish a new health plan. 

 Order on All Writs Act- Injunction