COLUMBUS, Ga. - A health plan's and plan sponsor's state law claims against a medical provider to recover benefits erroneously paid by the plan because of the provider's alleged fraudulent misrepresentations are completely preempted under the Employee Retirement Income Security Act, a federal judge in Georgia ruled May 22 (Aflac, Inc., et al. v. Richard Bloom, No. 4:12-CV-331, M.D. Ga.; 2013 U.S. Dist. LEXIS 72106).