of ERISA preemption have not affected the doctrine’s scope as it applies to common law claims based on i on Roessert v. Health Net, 929 F.Supp. 343 (N.D.Cal.1996), where plaintiffs alleged that the third party administrator became a provider of medical treatment when it directed a treating provider to commit a beneficiary diagnosed with chronic fatigue syndrome to a psychiatric facility. Id. at 351. Here the Dancas’ claims are based on the denial of authorization for admission to a specific psychiatric facility, not claims based on the pro-active efforts of claim administrators to commit to psychiatric hospitalization a person who had sought no such treatment. The Dancas’ claims are more analogous factually to those in Tolton v. American Biodyne, Inc., 48 F.3d 937, 942 (6th Cir.1995) (<HOLDING>). Had the Dancas sought review of PHCS’s
holding that a claim that unlawful termination resulted in loss of benefits is not preempted by erisa holding state law claims that fall outside the realm of  502 even if preempted by  514 remain governed by the wellpleaded complaint rule and are therefore not removable holding that erisa completely preempted certain state law claims and finding that erisa preempted an employees common law tort and contract claim when the employee sought benefits under the employers disability policy holding that the state law contract claim alleged the same conduct as in the erisa claim and was therefore preempted holding that a claim for refusing to authorize psychiatric benefits for treatment of severe substance abuse problem was preempted by  514 and  502 of erisa