1. Why did I receive a notice in the mail?
2. What is the Action about?
3. Why is this case a class action?
4. Why is there a settlement?
5. How do I know whether I am part of the Settlement Class?
6. What does the Settlement provide?
7. How much will my payment be?
8. How can I get a payment?
9. When will I get my payment?
10. Can I opt out of the Settlement?
11. Do I have a lawyer in the Action?
12. How will the lawyers be paid?
13. How do I tell the Court that I object to the Settlement?
14. When and where will the Court decide whether to approve the Settlement?
15. Do I have to come to the hearing?
16. May I speak at the hearing?
17. What happens if I do nothing at all?
18. Are there more details about the Settlement?
Class Members received a notice because they or someone in their family is or may have been a participant in or a beneficiary of the Plan at some time between December 29, 2017, through the present.
The Court ordered the Notice to be sent to Class Members because they have a right to know about the Settlement and all the options available to them regarding the Settlement before the Court decides whether to approve the Settlement. If the Court approves the Settlement, and after any objections and appeals are resolved, the Net Settlement Amount will be allocated among members of the Settlement Class according to a Court-approved Plan of Allocation.
The Court in charge of this case is the United States District Court for District of Massachusetts. The individuals who sued are called the “Plaintiffs,” and the parties they sued are called the “Defendants.” The legal Action that is the subject of the Notice and the Settlement is titled Hoye v. CHA General Services, Inc., Case No. 1:23-cv-13238 (D. Mass).
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The Action claims that the Defendants were fiduciaries to the Plan and violated statutory obligations under ERISA that Defendants owed to the Plan and the Plan’s participants and beneficiaries. Plaintiffs allege Defendants breached certain fiduciary duties by causing the Plan to incur higher administrative fees and expenses than reasonable and necessary. Plaintiffs also allege Defendants breached certain fiduciary duties by selecting and continuing to offer certain investment options to the Plan participants under the Plan’s investment lineups.
Defendants deny each and every allegation of wrongdoing made in the Complaint and contend that they have no liability in the Action. Defendants specifically deny the allegations that they breached any fiduciary duty or any other provisions of ERISA in connection with the administrative fees or expenses incurred by the Plan, or the investments in the Plan, and further deny that they in any way failed to act prudently or loyally to the Plan’s participants and beneficiaries.
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In a class action, one or more plaintiffs sue on behalf of a large number of people who have similar claims. All the individuals on whose behalf the plaintiffs are suing are “Class Members.” One court resolves the issues for all Class Members. In its order setting the Final Fairness Hearing, the Court preliminarily certified the Settlement Class in the Action.
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The Court has not reached any final decision in connection with Plaintiffs’ claims against the Defendants. Instead, Plaintiffs and Defendants have agreed to a Settlement. In reaching the Settlement, they have avoided the cost, risks, time, and disruption of prolonged litigation and trial.
Class Counsel believe that the Settlement is the best option for the Settlement Class members.
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The Court has held that this Settlement shall proceed on behalf of everyone who fits the following description:
“All persons who were participants in or beneficiaries of the Cambridge Health Alliance Partnership Plan at any time between December 29, 2017, and the date upon which this Preliminary Approval Order is entered.”
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The Settlement provides that CHA or Defendants’ insurers will pay $595,000.00 (the “Gross Settlement Amount”) into an account at a financial institution identified by the Settlement Administrator. The net amount of the Gross Settlement Amount, after payment of Court-approved attorneys’ fees and costs, and any expenses incurred administrating the Settlement, will be allocated to the members of the Settlement Class according to a Plan of Allocation to be approved by the Court if and when the Court enters an order finally approving the Settlement.
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If you qualify, you will receive a pro rata share of the Net Settlement Amount. Class Counsel have filed a detailed Plan of Allocation, which is available on the Important Documents page of this website. The Plan of Allocation describes the manner in which the Net Settlement Amount will be distributed to members of the Settlement Class. In general terms, the Plan of Allocation will provide that each Settlement Class member’s share of the Net Settlement Amount will be calculated as follows:
The Settlement Administrator will calculate an average account balance for each Settlement Class member based on his or her total annual-ending account balances invested in the Plan for the Class Period (“Average Account Balance”).
The Settlement Administrator will sum the Average Account Balances for all Settlement Class members.
The Settlement Administrator will then determine the total settlement payment available to each Settlement Class member by calculating each such person’s pro rata share of the Net Settlement Amount based on his or her Average Account Balance compared to the sum of the Average Account Balances for all Settlement Class members.
If the dollar amount of the settlement payment to a Settlement Class member is calculated by the Settlement Administrator to be less than $10.00, then that Settlement Class member’s payment or pro rata share shall be zero for all purposes.
The Settlement Administrator’s calculations regarding settlement payments will be final and binding under the Court-approved Plan of Allocation.
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If the Settlement is given final approval, you will not have to do anything to get a payment from the Settlement if you are entitled to one under the Plan of Allocation.
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The balance of the Net Settlement Amount will be allocated to members of the Settlement Class pursuant to the Plan of Allocation after final approval has been obtained for the Settlement, including any appeals. Any appeal of the final approval may take a year or more. Please be patient.
There will be no payments if the Settlement is terminated.
The Settlement may be terminated on several grounds, which are described in the Settlement Agreement. In the event any of these conditions occur, there will be no Settlement payment made, and the litigation will resume.
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No. In some class actions, class members have the opportunity to exclude themselves from the Settlement. This is sometimes referred to as “opting out” of the Settlement. Because of the legal issues involved in the Action, however, the class of participants affected by this Settlement has been preliminarily certified as a mandatory class. This means you cannot opt out of the benefits of the Settlement in order to pursue your own claims or for any other reason. Therefore, you will be bound by any judgments or orders that are entered in this Action, and if the Settlement is approved, you will be deemed to have released Defendants from any and all claims that were or could have been asserted in this case on your behalf or on behalf of the Plan or that are otherwise included in the release in the Settlement, other than your right to obtain the relief provided to you, if any, by the Settlement.
Although you cannot opt out of the Settlement, you can object to the Settlement and ask the Court not to approve the Settlement, as described in Question 13 below.
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The Court has designated Fair Work, P.C. as Class Counsel for the Settlement Class. If you want to be represented by your own lawyer, you may hire one at your own expense.
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Class Counsel will file a petition for an award of attorneys’ fees and expenses by April 14, 2026, after which a copy will be posted on the Important Documents page. This petition will be considered at the Final Fairness Hearing. Class Counsel have agreed to limit their application for an award of attorneys’ fees to not more than 33% of the Settlement Amount, plus out-of-pocket costs.
You have the right to object to this aspect of the Settlement even if you approve of the other aspects of the Settlement.
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You can tell the Court that you do not agree with the Settlement or some part of it.
If you are a member of the Settlement Class, you can object to the Settlement if you disagree with any part of it. You can give reasons why you think the Court should not approve the Settlement. The Court will consider your views. To object, you must send a letter or other written filing saying that you object to the Settlement. Be sure to include the following case caption and notation of: Hoye v. CHA General Services, Inc., Case No. 1:23-cv-13238 (D. Mass).
In addition, your objection must also include your name, address, telephone number, signature, and the reasons why you object to the Settlement. Any objection must be signed by the Settlement Class member even if an attorney is retained by the Settlement Class member.
Mail the objection to each of the addresses listed below, postmarked no later than April 28, 2026. You must mail your objection by this date. If you fail to do so, the Court will not consider your objection. If you plan to speak at the Fairness Hearing, you must send a Notice of Intention to Appear along with your objection, as described below:
Court Clerk | Plaintiffs’ Counsel (Class Counsel) | Defendants’ Counsel |
Clerk | Steve Churchill | Wesley E. Stockard |
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The Court will hold a Final Fairness Hearing to decide whether to approve the Settlement as fair, reasonable, and adequate. You may attend the Final Fairness Hearing, and you may ask to speak, but you do not have to attend. The Court will hold the Final Fairness Hearing on May 12, 2026, at 3:00 p.m. ET in Courtroom 20, 7th Floor of the U.S. District Court, John Joseph Moakley United States Federal Courthouse, 1 Courthouse Way, Suite 9200 Boston, MA 02210.
At that hearing, the Court will consider whether the Settlement is fair, reasonable, and adequate. If there are objections, the Court will consider them. After the Final Fairness Hearing, the Court will decide whether to approve the Settlement. The Court will also rule on the motions for attorney’s fees and expenses.
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No, but you are welcome to come at your own expense. If you send an objection, you do not have to attend the Fairness Hearing and voice your objection in person. As long as you mail your written objection on time, the Court will consider it when determining whether to approve the Settlement as fair, reasonable, and adequate. You also may pay your own lawyer to attend the Fairness Hearing, but attendance is not necessary.
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Only if you have previously filed an objection to the Settlement may you ask the Court for permission to speak at the Final Fairness Hearing. To do so, you must send a letter or other paper called a “Notice of Intention to Appear at Final Fairness Hearing,” in Hoye v. CHA General Services, Inc., Case No. 1:23-cv-13238 (D. Mass). Be sure to include your name, address, telephone number, and signature. Your Notice of Intention to Appear must be postmarked no later than April 28, 2026, and be sent to the Clerk of the Court, Class Counsel, and Defendant’s counsel at the addresses listed above.
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If you do nothing and you are a member of the Settlement Class and the Settlement is approved, you will participate in the Settlement of the Action as described in the Notice.
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This website and the Notice summarize the proposed Settlement. The complete Settlement is set forth in the Settlement Agreement. You may obtain a copy of the Settlement Agreement, along with other case-related documents, on the Important Documents page, or you may request one be mailed to you by contacting the Settlement Administrator at:
CHA ERISA Settlement
c/o Settlement Administrator
P.O. Box 25191
Santa Ana, CA 92799
Email: info@CambridgeHealthERISASettlement.com
Telephone: (844) 340-6953
Documents are also available at the office of the Clerk located at the U.S. District Court Courthouse, U.S. District Court, John Joseph Moakley United States Federal Courthouse, 1 Courthouse Way, Suite 9200, Boston, MA 02210.
If you have additional questions, you may contact the Settlement Administrator at the information above, or Class Counsel may be reached at:
Osvaldo Vazquez
FAIR WORK P.C.
192 South Street, Suite 450
Boston, MA 02111
Email: class.admin@fairworklaw.com
Telephone: (617) 607-3260
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