Can an arbitration clause be used in an ERISA regulated plan to cut off litigation?

The Ninth Circuit has upheld the use of an arbitration clause in a welfare benefit plan as a means of cutting off litigation. Although this decision does not necessarily apply in Florida, the decision is helpful to employers. It is now the law in the far West, which may be of help to those with West Coast employees. Presumably similar clauses can be used in other kinds of ERISA regulated plans.