In both the ERISA context and otherwise, health and disability insurance carriers continue to see claims seeking to expand the level of coverage offered under policies for illnesses most commonly considered mental illnesses. One of the more common bases for these claims is that the illnesses at issue may be biologically based. While these types of claims are not new, the types of illnesses for which such expanded coverage is sought continue to evolve. For instance, one carrier recently settled a class action where the insureds sought expanded coverage for eating disorders. Additionally, plaintiffs’ counsel continue to bring individual and class actions alleging that bipolar disorder is not a mental illness for purposes of policy limitations. As medical research continues into the origins of various mental illnesses, it may be expected that these types of claims, and types of illnesses at issue, will only continue to increase.