Tess Gee commented on additional challenges facing faith-based hospitals and their pension plans following the Supreme Court's decision that the plans are exempt from ERISA's pension guidelines. "What is left for plaintiffs to figure out is a way of challenging whether the organization administering or funding the plan is a principal purpose organization. That is going to be the next wave," Gee said, adding that courts will have to determine what the structure of the internal plan committee is and how it operates, who its members are, what functions the plan performs and the systems' relationship to their affiliated churches.