(United States Third Circuit) – In an action for unpaid insurance benefits brought under the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. section 1001 et seq., the district court’s dismissal for lack of standing under ERISA is reversed where a patient’s explicit assignment of payment of insurance benefits to her healthcare provider, without direct reference to the right to file suit, is sufficient to give the provider standing to sue for those benefits under ERISA section 502(a), 29 U.S.C. section 1132(a).