Skip to content

The Baldwin Group to go private. Read a message from our CEO here.

Baldwin Bulletin

JPMorgan ERISA Lawsuit Allowed to Proceed

The Baldwin Group
|
Updated: March 26, 2026
|
2 minute read

March 2026

Natashia Wright, Associate Director Benefits Compliance

On March 9, 2026, U.S. District Judge, Jennifer Rochon, ruled that JPMorgan Chase employees can move forward with portions of their lawsuit alleging the bank mismanaged its health and prescription benefits program. The plaintiffs claim that JPMorgan’s actions caused them to overpay for prescription drugs and premiums.

The proposed class action represents tens of thousands of workers and alleges that JPMorgan violated the Employee Retirement Income Security Act of 1974 (“ERISA”). The lawsuit focuses on the bank’s process for hiring CVS Caremark, a subsidiary of CVS Health, citing conflicts of interest due to CVS Health’s relationship as an investment banking client of JPMorgan.

While Judge Rochon dismissed allegations that JPMorgan breached certain fiduciary duties—stating that corporate decisions do not automatically become fiduciary acts under ERISA—she allowed claims related to “prohibited transactions” to continue. She noted that, based on a recent Supreme Court decision, plaintiffs only need to plausibly allege that such prohibited transactions took place; JPMorgan may still raise affirmative defenses as the case continues.

Recently, the courts have dismissed similar lawsuits against other major corporations, such as Wells Fargo & Co. and Johnson & Johnson. However, litigation against ERISA health plans has increased since the passage of the Consolidated Appropriations Act of 2021 which strengthened fee disclosure rules for service providers, including pharmacy benefit managers (“PBMs”).

The U.S. Department of Labor recently proposed new ERISA rules to improve transparency around PBM compensation. These rules would require PBMs to disclose all forms of direct and indirect compensation, including payments from drug manufacturers, spread compensation, and price protection arrangements, among others.

Further, the Consolidated Appropriations Act of 2026 will require PBMs to regularly report details about prescription drug benefits, including out-of-pocket costs for participants and reimbursement amounts to pharmacies. As scrutiny of health plan fees and PBM arrangements grows, experts anticipate more class action lawsuits. The JPMorgan case highlights the importance of health plan sponsors closely monitoring service providers, reviewing fee disclosures, and maintaining thorough documentation to defend against potential litigation and fulfill their fiduciary responsibilities under ERISA.

  • Stay informed about ongoing legal developments and class action trends affecting employer-sponsored health plans to anticipate and mitigate your litigation risks.
  • If needed, work with your broker for guidelines to meet ERISA fiduciary responsibilities.
  • Review and strengthen oversight of health and prescription benefits programs to ensure compliance with ERISA and to avoid potential conflicts of interest.
  • Establish procedures for regular reporting of prescription drug benefit details, including participant out-of-pocket costs and pharmacy reimbursement amounts, as required by future legislation.
  • Prepare for new ERISA regulations by ensuring PBMs disclose all forms of compensation, including direct and indirect payments, spread compensation, and price protection arrangements.

Related Insights

Stay in the know

Our experts monitor your industry and global events to provide meaningful insights and help break down what you need to know, potential impacts, and how you should respond.

Compliance Alert
New Guidance on Trump Accounts and Employer Contributions
Overview On September 30, 2026, the Treasury Department and the Internal Revenue Service (“IRS”) issued temporary regulations (TD 10056) providing...
Baldwin Bulletin
MHPAEA Enforcement Update: What Employers Should Review Now
Stephanie Hall, Associate Director Benefits Compliance In keeping with its updated national enforcement priorities for fiscal year 2026, the U.S....
Baldwin Bulletin
No Surprises Act – Changes to the Independent Dispute Resolution Process
Deanna J. Sizemore, Director, Benefits Compliance For nearly four years, the No Surprises Act's (“NSA”) Independent Dispute Resolution (“IDR”) process...
Baldwin Bulletin
DOL Proposes New Electronic Delivery Safe Harbor Under ERISA
Caitlin Hillenbrand, Associate Director Benefits Compliance On July 23, 2026, the U.S. Department of Labor’s (“DOL”) Employee Benefits Security Administration...
Baldwin Bulletin
Proposed IRS Regulations Could Simplify DCAP Nondiscrimination Testing
Paul Van Brunt, Sr. Associate Director Benefits Compliance The Internal Revenue Service (“IRS”) and U.S. Treasury Department (“Treasury”) recently issued...
Let's make it possible

Partner with us to build solutions that align with your business, individual, or employee needs and open new possibilities for your future.

Connect with us