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Returning the ERISA Case to the Plan Administrator: Administrative Agency Analogies
Health Plan Law 
Aug. 28, 2007
Excerpt: One of the ironies of ERISA jurisprudence lies in the variety of judicial conclusions as to how claims must be advanced and evaluated under its purportedly 'comprehensive and reticulated' scheme. Graham v. Hartford underscores this point in the Tenth Circuit's review of the variety of channels open to parties after a determination on a claim for benefits by a plan administrator.
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