DETROIT - Blue Cross Blue Shield of Michigan engaged in self-dealing in violation of the Employee Retirement Income Security Act, 29 U.S.C.S. § 1001 et seq., by charging self-insured welfare plans and their sponsors an administrative fee and unilaterally determining the amount of the fee, a federal judge in Michigan ruled Sept. 7 in granting summary judgment against Blue Cross on prohibited transaction claims (Borroughs Corporation, et al, v. Blue Cross Blue Shield of Michigan, Nos. 11-12565, 11-12557, E.D. Mich.; 2012 U.S. Dist. LEXIS 127587).