gobeille chair vermont green mountain care board liberty mutual insurance argued december decided march vermont law requires certain entities including health insurers report payments relating health care claims information relating health care services state agency compilation health care database respondent liberty mutual insurance company health plan plan provides benefits employee welfare benefit plan employee retirement income security act erisa plan administrator blue cross blue shield massachusetts blue cross subject vermont disclosure statute ordered transmit files eligibility medical claims pharmacy claims plan vermont members respondent concerned disclosure confidential information might violate fiduciary duties instructed blue cross comply filed suit seeking declaration erisa application vermont statute regulation plan injunction prohibiting vermont trying acquire data plan members district granted summary judgment vermont second circuit reversed concluding vermont reporting scheme erisa held erisa vermont statute applied erisa plans pp erisa expressly state laws insofar may hereafter relate employee benefit plan relevant clause state law impermissible connection erisa plans law governs interferes uniformity plan administration egelhoff egelhoff pp considerations relevant determination whether impermissible connection exists erisa objectives guide scope state law congress understood survive new york state conference blue cross blue shield plans travelers ins nature state law effect erisa plans california div labor standards enforcement dillingham lead conclusion vermont regime applied erisa plans pp erisa seeks make benefits promised employer secure mandating certain oversight systems standard procedures travelers systems procedures intended uniform erisa extensive reporting disclosure recordkeeping requirements central essential part uniform plan administration system vermont law regulation however also govern plan reporting disclosure recordkeeping necessary order prevent multiple jurisdictions imposing differing even parallel regulations creating wasteful administrative costs threatening subject plans liability erisa uniform rule design also makes clear secretary labor separate authorized decide whether exempt plans erisa reporting requirements require erisa plans report data sought vermont pp vermont counterarguments unpersuasive vermont argues respondent shown state scheme caused suffer economic costs respondent need wait bring claim confronted numerous inconsistent obligations encumbered ensuing costs addition fact erisa state reporting scheme different objectives transform vermont direct regulation fundamental erisa function innocuous peripheral set additional rules vermont regime also saved invoking state traditional power regulate area public health pp erisa reporting disclosure recordkeeping provisions maintain force regardless whether new patient protection affordable care act reporting obligations also state law pp affirmed kennedy delivered opinion roberts thomas breyer alito kagan joined thomas breyer filed concurring opinions ginsburg filed dissenting opinion sotomayor joined opinion notice opinion subject formal revision publication preliminary print reports readers requested notify reporter decisions washington typographical formal errors order corrections may made preliminary print goes press alfred gobeille official capacity chair vermont green mountain care board petitioner liberty mutual insurance company writ certiorari appeals second circuit march justice kennedy delivered opinion case presents challenge applicability state law requiring disclosure payments relating health care claims information relating health care services vermont enacted statute maintain health care database stat tit cum supp state law terms applies health plans established employers regulated employee retirement income security act erisa stat amended et seq question whether erisa vermont statute applies erisa plans vermont requires certain public private entities provide pay health care services report information state agency reported information compiled database reflecting health care utilization costs resources vermont health care utilization costs services provided vermont residents another state database kind sometimes called claims database requires submission data health insurers entities pay health care services almost implementing similar databases see brief state new york et al amici curiae vermont law requires health insurers health care providers health care facilities governmental agencies report information relating health care costs prices quality utilization resources required state agency including data relating health insurance claims enrollment health insurers must submit claims data members subscribers policyholders vermont law defines health insurer include health care benefit plan well third party administrator similar entity claims data eligibility data provider files information relating health care provided vermont resident database must made available resource insurers employers providers purchasers health care state agencies continuously review health care utilization expenditures performance vermont vermont law leaves state agency responsibility establish types information filed section time place manner information shall filed law implemented regulation creating vermont healthcare claims uniform reporting evaluation system regulation requires submission medical claims data pharmacy claims data member eligibility data provider data information reg code rules cvr accordance specific formatting coding requirements regulation health insurers must report data health care services provided vermonters regardless whether treated vermont treated vermont see also agency present collect data denied claims statute allow covered entities reporters must register state must submit data monthly quarterly annually depending number individuals entity serves people served frequently reports must filed entities fewer members need report termed voluntary reporters distinct mandated reporters reporters fined complying statute regulation respondent liberty mutual insurance company maintains health plan plan provides benefits individuals comprising respondent employees families former employees plan means plan benefits paid respondent plan qualifies employee welfare benefit plan erisa subject erisa comprehensive regulation new york state conference blue cross blue shield plans travelers ins respondent plan sponsor fiduciary plan administrator plan uses blue cross blue shield massachusetts blue cross administrator blue cross manages processing review payment claims respondent liberty mut ins donegan case contract blue cross respondent agreed hold blue cross harmless charges including legal fees judgments administrative expenses benefit payment requirements arising connection plan due respondent failure comply laws regulations app plan voluntary reporter vermont regulation covers vermonters fewer cutoff mandated reporting blue cross however serves several thousand vermonters mandated reporter blue cross therefore must report information possesses plan members vermont august vermont issued subpoena ordering blue cross transmit contractor files possessed member eligibility medical claims pharmacy claims vermont members clarity uses vermont refer state also state officials acting official capacity penalty noncompliance vermont threatened fine day suspension blue cross authorization operate vermont long six months respondent concerned part disclosure confidential information regarding members might violate fiduciary duties plan instructed blue cross comply respondent filed action district district vermont sought declaration erisa application vermont statute regulation plan injunction forbidding vermont trying acquire data plan members vermont filed motion dismiss district treated one summary judgment see fed rule civ proc respondent filed summary judgment district granted summary judgment vermont first held respondent despite mere voluntary reporter standing sue faced either allegedly violating fiduciary administrative responsibilities plan assuming liability blue cross withholding data vermont liberty mut ins kimbell district concluded state reporting scheme although scheme may indirect effect health benefit plans reasoned effect peripheral regulation considered attempt interfere administration structure welfare benefit plan appeals second circuit reversed panel unanimous concluding respondent standing divided merits challenge panel majority explained one erisa core functions reporting laden burdens subject incompatible multiple variable demands freighted risk fines breach duty legal expense vermont regime held granted certiorari address important issue erisa ii text erisa express clause necessary starting point terse comprehensive erisa state laws insofar may hereafter relate employee benefit plan addressed potential reach clause travelers observed taken extend furthest stretch indeterminacy practical purposes never run course result sensible person intended california div labor standards enforcement dillingham scalia concurring need workable standards led reject uncritical literalism applying clause travelers implementing principles case law date described two categories state laws erisa first erisa state law erisa plans ibid precise state law acts immediately exclusively upon erisa plans existence erisa plans essential law operation result dillingham supra second erisa state law impermissible connection erisa plans meaning state law governs central matter plan administration interferes nationally uniform plan administration egelhoff egelhoff state law also might impermissible connection erisa plans acute albeit indirect economic effects state law force erisa plan adopt certain scheme substantive coverage effectively restrict choice insurers travelers supra considered together formulations ensure erisa express clause receives broad scope congress intended avoiding clause susceptibility limitless application iii respondent contends vermont law falls second category state laws erisa laws govern interfere uniformity plan administration impermissible erisa plans egelhoff supra travelers presented contentions earlier cases considered objectives erisa statute guide scope state law congress understood survive nature effect state law erisa plans dillingham supra considerations lead conclude vermont regime applied erisa plans erisa guarantee substantive benefits statute instead seeks make benefits promised employer secure mandating certain oversight systems standard procedures travelers systems procedures intended uniform erisa clause indicates congress intent establish regulation employee welfare benefit plans exclusively federal quoting alessi requiring erisa administrators master relevant laws contend litigation undermine congressional goal ing administrative financial burden plan administrators burdens ultimately borne beneficiaries egelhoff supra quoting mcclendon see also fort halifax packing coyne erisa reporting disclosure recordkeeping requirements welfare benefit plans extensive erisa plans must present participants plan description explaining among things plan eligibility requirements procedures plans must notify participants claim denied state basis denial important question presented welfare benefit plans governed erisa must file annual report secretary labor report must include financial statement listing assets liabilities previous year receipts disbursements funds information assets liabilities well receipts disbursements must provided plan participants annual basis well welfare benefit plans business providing benefits plan participants plan reporting data disbursements definition incorporates paid claims see dept labor schedule form financial information requiring reporting enefit claims payable enefit payment payments provide benefits online http last visited secretary labor authority establish additional reporting disclosure requirements erisa plans erisa permits secretary use data disclosed plans statistical research purposes compile publish studies analyses reports surveys based thereon may deem appropriate secretary also may connection research collect compile analyze publish data information statistics relating plans see also approving studies relating employee benefit plans matters regulated subchapter enforcement procedures provided subchapter erisa permits secretary labor requir information data plan finds data information necessary carry purposes statute investigating possible statutory violation require submission reports books records filing data related requisite filings secretary general power promulgate regulations necessary appropriate administer statute provide exemptions reporting obligations come surprise plans must keep detailed records compliance erisa reporting disclosure requirements may verified explained clarified checked accuracy completeness records retained must include vouchers worksheets receipts applicable resolutions ibid see also allowing secretary provide keeping books records inspection books records various requirements mere formalities violation one may result civil criminal liability see makes plain reporting disclosure recordkeeping central essential part uniform system plan administration contemplated erisa fact noted often requirements integral aspects erisa see dillingham travelers supra supra massachusetts morash fort halifax supra metropolitan life ins massachusetts vermont reporting regime compels plans report detailed information claims plan members intrudes upon central matter plan administration interferes nationally uniform plan administration egelhoff state law regulation govern plan reporting disclosure necessary implication recordkeeping matters fundamental components erisa regulation plan administration differing even parallel regulations multiple jurisdictions create wasteful administrative costs threaten subject plans liability see supplying penalties violation vermont reporting rules cvr necessary prevent imposing novel inconsistent burdensome reporting requirements plans secretary labor authorized administer reporting requirements plans governed erisa may exempt plans erisa reporting requirements altogether see cfr exempting health plans annual financial reporting requirement may authorized require erisa plans report data similar vermont seeks though question presented either way uniform rule design erisa makes clear decisions federal authorities separate vermont disputes reporting regime several fronts state argues respondent demonstrated reporting regime fact caused suffer economic costs brief petitioner respondent challenge based theory state law must solely economic burdens caused state law see travelers respondent argues rather vermont scheme regulates central aspect plan administration scheme plans face possibility body disuniform state reporting laws even uniform necessity accommodate multiple governmental agencies plan need wait bring claim confronted numerous inconsistent obligations encumbered ensuing costs vermont contends furthermore erisa state statute regulation state reporting scheme different objectives recognized principal object erisa protect plan participants beneficiaries boggs boggs enacting erisa congress primary concern mismanagement funds accumulated finance employee benefits failure pay employees benefits accumulated funds morash supra state maintains program nothing financial solvency plans prudent behavior fiduciaries see brief petitioner suffice avoid federal claims turn congress intent travelers purpose state law relevant may relate scope state law congress understood survive nature effect state law erisa plans dillingham supra travelers example noted oth purpose effects state law issue distinguish ed laws function regulation erisa plan perceived difference objectives vermont law erisa shield vermont reporting regime vermont orders health insurers including erisa plans report detailed information administration benefits systematic manner direct regulation fundamental erisa function difference purpose transform direct regulation central matter plan administration egelhoff supra innocuous peripheral set additional rules vermont regime saved invoking state traditional power regulate area public health past addressed claims starting presumption congress intend supplant state law particular state laws regulating subject traditional state power travelers supra erisa however certainly contemplated substantial areas traditional state regulation dillingham erisa state law regulates key facet plan administration even state law exercises traditional state power see egelhoff fact reporting principal essential feature erisa demonstrates congress intended state reporting laws like vermont including operate purpose furthering public health analysis may different applied state law tax hospitals see de buono medical clinical services fund enforcement necessitates incidental reporting erisa plans law presumption whatever force instances validate state law enters fundamental area erisa regulation thereby counters federal purpose way state law iv respondent suggests patient protection affordable care act aca created new reporting obligations health plans incorporated requirements body erisa demonstrates erisa vermont reporting regime see aca however specified shall construed preempt state law prevent application provisions aca provision might prevent new reporting obligations state reporting regimes like vermont notwithstanding incorporation requirements heart erisa see providing new aca provisions shall construed affect modify erisa clause applied group health plans need resolve issue erisa reporting disclosure recordkeeping provisions upon conclusion rests maintain force whether new aca reporting obligations also state law erisa express clause requires invalidation vermont reporting statute applied erisa plans state statute imposes duties inconsistent central design erisa provide single uniform national scheme administration erisa plans without interference laws several even laws large extent impose parallel requirements judgment appeals second circuit affirmed thomas concurring alfred gobeille official capacity chair vermont green mountain care board petitioner liberty mutual insurance company writ certiorari appeals second circuit march justice thomas concurring join opinion faithfully applies precedents interpreting express provision employee retirement income security act erisa write separately come doubt whether valid exercise congressional power whether approach erisa consistent broader jurisprudence section contains may expansive express provision federal statute section except provided erisa shall supersede state laws insofar may hereafter relate employee benefit plan ordinary meaning phrase relate state laws bearing bring association connection erisa plan shaw delta air lines quoting black law dictionary ed seemingly acknowledges broadly extends excepting generally applicable criminal law state laws regulat ing insurance banking securities generally applicable civil laws section sum clearly expansive much one might excused wondering first blush whether words limitation relate much limiting new york state conference blue cross blue shield plans travelers ins read according plain terms raises constitutional concerns supremacy clause gives status federal laws constitution wyeth levine thomas concurring judgment quoting art vi cl question whether provision article authorizes congress prohibit applying host generally applicable civil laws erisa plans constitution requires distinction truly national truly local morrison federal government take regulation entire areas traditional state concern including areas nothing regulation commercial activities boundaries spheres federal state authority blur political responsibility become illusory lopez kennedy concurring congress regulate aspects erisa plans pursuant commerce clause mean congress exempt erisa plans state regulations nothing interstate commerce see gonzales raich thomas dissenting ii used interpret according text became uncomfortable much state law read literally taken extend furthest stretch indeterminacy explained practical purposes never run course travelers supra rather addressing constitutionality abandoned efforts give text ordinary meaning travelers adopted atextual thought workable standards construe ante thus determine whether state law impermissibly relates erisa plan due connection plan look objectives erisa statute well nature effect state law erisa plans egelhoff egelhoff citing travelers internal quotation marks omitted decided travelers joined opinion joined others applying approach adopted travelers interpretation erisa express provision become increasingly difficult reconcile jurisprudence travelers departed statutory text deeming unhelpful cases involving express provisions text beginning often end analysis chamber commerce america whiting ing plain define scope immigration reform control act express clause see also national meat assn harris slip parsing text determine scope federal meat inspection act express clause likewise refused look policy limits remotely discernible statutory text whiting supra given sound basis departing principles treating differently express provisions travelers approach erisa also avoid constitutional concerns continued interpret substantial areas traditional state regulation ing state law even state law exercises traditional state power ante internal quotation marks omitted confront whether congress constitutional authority wide array state laws first place lower courts continue struggle apply behooves us address whether article gives congress power whether may permissibly read avoid unconstitutional results breyer concurring alfred gobeille official capacity chair vermont green mountain care board petitioner liberty mutual insurance company writ certiorari appeals second circuit march justice breyer concurring write separately emphasize failure find subject health plans employee retirement income security act erisa stat amended et potentially conflicting information reporting requirements likely create serious administrative problems points respondent plan provides benefits individuals living different see ante addition amici curiae tell us health plans provide benefits million americans brief american benefits council et al amici curiae state free go way independently determining information plan must provide benefits result well unnecessary duplicative conflicting reporting requirements mean increased confusion increased cost private standard setting course help alleviate problems given large number different possible regulations believe sufficient cf costello taylor apcd council nahdo standardization data collection claims databases online https last visited also emphasize necessarily prevent vermont obtaining information need wishing obtain information ask federal government appropriate approval majority points secretary labor authority establish additional reporting disclosure requirements erisa plans ante see moreover secretary authorized undertake research surveys connection therewith collect compile analyze publish data information statistics relating employee benefit plans including retirement deferred compensation welfare plans least one important statute provides secretary health human services similar authority see part patient protection affordable care act applicable group health insurance plans including erisa plans brief amicus curiae department labor department health human services department treasury currently considering rulemaking require health plans report detailed information various aspects plan administration enrollment claims processing benefit offerings see reason secretary labor develop reporting requirements satisfy needs including requirements appropriate see department delegate particular state authority obtain data related state also providing data federal secretary use federal level although need federal approval authorization limits degree power obtain information requiring approval considerable advantages federal agencies likely informed understand consequences needs national perspective involvement may consequently secure necessary information without unnecessarily creating costly conflicts particularly compared alternatives giving state free rein go way asking nonexpert federal courts try iron regulation regulation conflicts cf tronic lohr breyer concurring part concurring judgment reading complex ambiguous regulatory statute permit informed agency involvement likely achieve congress general objectives reasons others majority sets forth agree vermont statute interferes nationally uniform plan administration egelhoff egelhoff ginsburg dissenting alfred gobeille official capacity chair vermont green mountain care board petitioner liberty mutual insurance company writ certiorari appeals second circuit march justice ginsburg justice sotomayor joins dissenting better control health care outcomes costs vermont requires public private entities pay health care services provided vermont residents supply data state claims database many similar databases place development question presented case whether vermont health care law preempted employer retirement income security act erisa stat et federal law regulating employee benefit plans hold vermont effort track health care services provided residents cost services impermissibly intrude erisa dominion employee benefit plans vermont legislature established vermont health care uniform reporting evaluation system database populated information health care claims paid insurers coverage providers see stat tit cum supp reg code rules directing insurers coverage providers submit medical claims data pharmacy claims data member eligibility data provider data information related health care provided vermont residents health care provided vermont health care providers facilities health insurers coverage providers must report required data cover least vermont residents ab seventeen enacted similar database systems called claims databases like vermont collect data serve compelling interests including identification reforms effective drive health care costs evaluation relative utility different treatment options detection instances discrimination provision care see brief national governors association et al amici curiae brief harvard law school center health law policy innovation et al amici curiae brief state new york et al amici curiae see also stat tit vermont law designed help identif health care needs infor health care policy evaluat effectiveness intervention programs improving patient outcomes compar costs various treatment settings approaches determin capacity distribution existing resources provid information purchasers health care respondent liberty mutual insurance company liberty common legions employers provides health care employees plan administered blue shield blue cross blue cross administers thousands health care policies vermont state requires report data plans administers blue cross complied mandate example blue cross reported data vermont health beneficiaries roughly half beneficiaries received coverage employer policies app liberty request blue cross submit data vermont residents received coverage liberty plan vermont ordered blue cross provide claims data liberty instructed blue cross comply shortly thereafter filed instant suit seeking block vermont obtaining data defense resistance vermont law liberty relies plan status employee welfare benefit plan defined plan fund program established maintained employer purpose providing participants beneficiaries purchase insurance otherwise medical surgical hospital care benefits benefits event sickness erisa directs plan fiduciaries conserve plan assets purpose providing benefits participants ii liberty maintains erisa preempts diverse state reporting laws mandatory reporting erisa plans liberty urges source mandate uniform national reporting regime see brief respondent tr oral arg opposing preemption law vermont points efficacy state law depends comprehensive reporting collecting data numerous beneficiaries several major segments health care market see brief petitioner brief harvard law school center health law policy innovation et al amici curiae half americans health insurance receive coverage employers dept commerce bureau census smith medalia health insurance coverage persons covered employer plan brief harvard law school center health law policy innovation et al amici curiae vermont database total content originates employer plans brief petitioner stopping collecting claims data employer health care plans thus hugely undermine reporting regimes vermont depend maintain improve quality hold cost health care services district district vermont rejected liberty plea preemption vermont law determined served state undoubted interest regulating health care markets substantially interfere operation liberty erisa plans see app pet cert appeals second circuit reversed two one liberty mut ins donegan majority acknowledged decisions marked something pivot starting presumption congress intend supplant state law especially action occurs fields traditional state regulation like health care quoting new york state conference blue cross blue shield plans travelers ins nonetheless majority concluded erisa preempted application vermont law liberty plan reporting information plan benefits majority reasoned qualifies core erisa functio therefore must subject uniform federal standard judge straub dissented offering concise critique majority opinion majority finds burden imposed vermont reporting requirement warrants preemption statute conclusion falters two primary reasons first reporting requirement imposed vermont statute differs kind required erisa therefore kind state law congress intended preempt second liberty mutual failed show actual burden much less burden triggers erisa preemption rather vermont statute interfere erisa plan administration benefits ii essentially reasons judge straub identified hold erisa preempt vermont statute law erisa serve different purposes erisa domain design administration employee benefit plans notably prescriptions vesting benefits claims processing designation beneficiaries see travelers congress intended ensure plans plan sponsors subject uniform body benefits law internal quotation marks omitted reporting requirements geared functions ensure plans fact provide covered benefits vermont statute contrast aims improve quality utilization reduce cost health care vermont providing consumers government officials researchers comprehensive data health care delivery system vermont law impose burdens erisa plans kind found sufficient warrant preemption erisa preemption clause provides act shall supersede state laws insofar may hereafter relate employee benefit plan lacking clear direction clause opaque text de buono medical clinical services fund sought honor congress evident call expansive preemption principle without invalidating state regulations falling outside erisa domain see travelers governing text erisa preemption clause clearly expansive taken extend furthest stretch indeterminacy practical purposes never run course really universally relations stop nowhere internal quotation marks omitted seeking bring measure determinacy erisa preemption stated law employee benefit plan connection reference plan internal quotation marks omitted case appeals found parties contest vermont law lacks reference erisa plans law applies health care payers home erisa plans see question therefore whether law impermissible connection erisa plans term scarcely restrictive cautioned uncritical literalism egelhoff egelhoff internal quotation marks omitted set formulation determine whether state law forbidden connection look objectives erisa statute guide scope state law congress understood survive well nature effect state law erisa plans ibid internal quotation marks omitted framing preemption doctrine assum lightly congress derogated state regulation instead addresse claims starting presumption congress intend supplant state law travelers especially state regulation deals matters health safety de buono internal quotation marks omitted travelers subsequent decisions upholding state laws preemption challenges made clear presumption plays important role erisa cases travelers california div labor standards enforcement dillingham de buono vermont law vital part state control health care market see supra straub dissenting presumption preemption thus apply full strength liberty rebutted shown erisa demands preemption vermont law contrary erisa preemption precedent points preemption case determine whether vermont law applied liberty plan impermissible connection erisa plans look first objectives erisa statute guide egelhoff oneok learjet slip emphasizing importance considering target state law aims applying ordinary principles erisa reporting requirements vermont law elicit different information serve distinct purposes sensible reason find vermont law preempted benefit plans must absent exemption file annual reports containing financial actuarial data enable secretary labor evaluate plans management solvency see dillingham congress established extensive reporting requirements protect mismanagement funds accumulated finance employee benefits failure pay employees benefits accumulated funds internal quotation marks omitted beyond debate vermont law seek regulate management solvency welfare plans see supra reciting objectives vermont law vermont requests information plan finances see reg code rules supra detailing types data collected vermont state collects data paid health care claims denied claims see vermont seeks better understanding residents obtain health care effective care unlike erisa superintendence vermont interest lie reviewing whether provider keeping bargain covered employees vermont statute even arguably regulate relationships among prime erisa entities beneficiaries participants administrators employees trustees fiduciaries plan despite significant differences erisa reporting requirements vermont regime liberty contends congress intended spare erisa plans reporting requirements unless requirements nationally uniform support contention liberty points dicta opinions selections erisa legislative history see travelers ubject matters covered erisa include reporting disclosure fiduciary responsibility like quoting shaw delta air lines mcclendon erisa sets various uniform standards including rules concerning reporting disclosure fiduciary responsibility pension welfare plans cong rec remarks javits state laws compelling disclosure plans far unambiguously endorsing liberty sweeping view erisa preemptive scope statements read least reasonably unremarkable principle erisa preempts state reporting rules designed serve purposes erisa reporting requirements limited understanding consistent admonition pay close attention objectives erisa statute guide egelhoff satisfied erisa objectives require preemption vermont law turn nature effect state law erisa plans ibid imposition burdens administration erisa plans held suffice require preemption see de buono law imposing costs acute effectively dictate plan designed administered trigger preemption see extreme effects present moreover central matter plan administration egelhoff touched vermont law law prescribes vesting requirements benefit levels beneficiary designations rules claims processed paid indeed vermont law require liberty anything burden compliance falls blue cross apparently provides data without protest behalf plans see supra reporting disclosure doubt required erisa plans requirements ancillary areas erisa governs reporting recordkeeping incident state laws general applicability upheld bear erisa plans de buono example held tax patient services provided hospital operated erisa plan preempted even though administration tax required filing quarterly reports dillingham held california law preempted applied apprenticeship programs established erisa plans laws typically require employees keep records wages paid employees make available review state authorities see cal lab code ann west law dillingham second circuit erred holding erisa preempts reporting obligation slight see vermont statute keeps company laws considered de buono dillingham generally applicable involve central matter plan administration egelhoff judge straub emphasized dissent liberty failed provide details showing alleged burden instead arguing regulations costs quoting liberty appellate brief explains supposition indulged second circuit vermont law imposed substantial burden obvious even particularly plausible without factual support brief amicus curiae law essentially requires blue cross liberty administrator take information generated ordinary course operations report information prescribed format state ibid appeals majority accentuated sheer number data entries must reported vermont see accord ante opinion breyer entirely overlooked enumeration technological capacity efficient data storage formatting submission see brief national association health data organizations et al amici curiae describing electronic path data take health provider insurer health care plan ultimately state database regulatory compliance depends upon use evolving technologies incumbent objector show concretely alleged regulatory burden fact laws like vermont uniform state state compliance inevitably burdensome liberty successfully argued appeals replays reasoning today opinion see ante diversity hallmark political system lauded opinions see arizona state legislature arizona independent redistricting slip long recognized role laboratories devising solutions difficult legal problems citing new state ice liebmann brandeis dissenting internal quotation marks omitted something inherent characteristic federal system therefore must underpin preemption liberty liberty points egelhoff exemplary egelhoff deceased participant challenged state law revoked beneficiary status automatically upon divorce even though erisa plan terms held erisa preempted law binds erisa plan administrators particular choice rules determining beneficiary status context said requiring erisa administrators master relevant laws undermine congressional goal minimizing administrative financial burdens plan administrators burdens ultimately borne beneficiaries internal quotation marks brackets omitted took care however confine egelhoff issues implicating central matter plan administration words core erisa concern category comprise earlier described see supra prescriptions benefit levels beneficiary designations vesting requirements rules processing payment claims rank central core erisa reporting disclosure obligations kind regulation design administration employee benefit plans reporting disclosures tied areas erisa governs erisa reporting disclosure requirements thus concerned mismanagement funds failure pay employee benefits plan assets allocations information bearing financial integrity plan see supra vermont law eliciting information medical claims services provided beneficiaries charges payment services demographic makeup receiving benefits fit bill reporting relating plan taxes wage payments numerous informed urgent need information yielded health care laws see brief national governors association et al amici curiae brief state new york et al amici curiae brief connecticut health insurance exchange amicus curiae brief state new hampshire amicus curiae wait federal government acts response department labor capacious grant statutory authority observes might allow collect data vermont seek erisa plan payments see ante ante opinion breyer information collected conjectures department pass data cf ante opinion breyer suggesting seek department permission enforce reporting requirements like vermont unsettling however leave dependent federal agency grace department labor willingness take chore divorced erisa declaring reporting unmodified central core erisa function second circuit passes line drew travelers de buono dillingham reined longer operate provision bogan protecting patient rights despite erisa tulane rev see supra dissent retrieval preemption doctrine belongs discard bin footnotes addition vermont far maintaining claims databases arkansas colorado connecticut kansas maine maryland massachusetts minnesota new hampshire new york oregon rhode island tennessee utah virginia washington west virginia brief national governors association et al amici curiae illustrative utility claims databases minnesota evaluated data visits concluded condition causing two every three visits treated efficiently effectively nonhospital setting brief state new york et al amici curiae liberty plan trigger vermont reporting requirements plan participants resided state total individuals covered liberty plan app pet cert federal government supplies medicare claims data vermont maintain similar databases see requiring department health human services hhs make medicare data available state databases hhs authorized include medicaid claims data databases see brief amicus curiae joined opinions proposing acknowledge clause provision meant set forth test rather identify field ordinary field applies namely field laws regulating plans california div labor standards enforcement dillingham scalia concurring egelhoff egelhoff scalia concurring whether measured ordinary preemption principles precedent vermont law survive inspection suggests department labor collects pursuant erisa reporting rules similar information data vermont regime elicits see ante reporting obligations remotely similar one liberty amici curiae explains department labor reporting form cited requires reporting total amount claims paid annually plan granular information including data location services rendered vermont collects brief national coordinating committee multiemployer plans amicus curiae see also reply brief data entries cited require plan enter merely handful boxes form aggregate sums claims paid annually see dept labor schedule form financial information online http internet materials last visited amici supporting liberty point several allegedly burdensome features compliance vermont law appear everyday facets modern regulatory compliance installing maintaining software system collect remit data state seeking variances state regulators health providers submit required information plan administrator reformatting data comply formatting encryption standards see brief blue cross blue shield association amicus curiae nn brief national coordinating committee multiemployer plans amicus curiae liberty contends need quantify precise cost compliance vermont law prove law burdensome liberty least introduce concrete evidence alleged burdens finder fact reasonably ask example blue cross existing technologies data storage already capacity store report data sought vermont compliance vermont reporting rules burdensome compliance state reporting laws plan already complies concurring opinion justice breyer worries state free go way result well unnecessary duplicative conflicting reporting requirements ante support justice breyer cites report costello taylor apcd council nahdo standardization data collection claims databases online https publication fact organizations published report inform us brief supporting vermont submitting claims data claims databases routine straightforward process private organizations worked recent years standardize requirements brief national association health data organizations et al amici curiae core erisa concern central matter plan administration inquiry meaningfully different examination whether state law inconsistent objectives erisa statute egelhoff see supra appears disagree stating ny difference purpose erisa vermont reporting requirements transform vermont direct regulation matter plan administration innocuous peripheral set additional rules ante quoting egelhoff words assumes state law inconsistent erisa purposes nonetheless burden central matter plan administration implicate core erisa concern missing opinion definition terms meaning central matter plan administration core erisa concern divorced erisa purposes analysis may hamper abilities require reporting plan benefits plan assets well example department labor collects information real property held trust pension plan assess plan financial see tr oral arg may need collect information different purpose assessing property tax