It was already pretty clear cut, but this decision also further clarifies that states can protect residents enrolled in ERISA plans from surprise billing through approaches like a simple ban on surprise billing by providers, network matching, or limits on out-of-network charges. https://twitter.com/efusebrown/status/1337102497652088835

Indeed, Indiana's new surprise billing protection should do just this (protect residents enrolled in self-insured employer plans), although they only applied the simple surprise billing ban approach to non-emergency services.

For more detail on how to think about ERISA in the context of regulations that affect costs for self-insured plans, @clinkeyoung & Mark Hall wrote a helpful appendix to our paper on state surprise billing solutions: https://www.brookings.edu/research/state-approaches-to-mitigating-surprise-out-of-network-billing/