arrowThe state of Michi­gan levies a tax on health claims made under self fund­ed plans – 1% flat to those ren­dered in state to in state res­i­dents, along with record­keep­ing and report­ing oblig­a­tions.  The Supreme Court has vacat­ed its ear­li­er rul­ing and the Sixth Cir­cuit has con­clud­ed that ERISA does not pre­empt the tax.  Will oth­er states fol­low?  A great way to make mon­ey but not so great for self fund­ed plans try­ing to save it.